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<br />:_ <br />J. ~. STOVER & ASSOCI~ES <br />2768 COMPASS DRIVE, SUITE 101 <br />GRAND JUNCTION, COLORADO 81506 <br />PHONE: (970) 245-4101, FAX 242-7908 <br />llINB SAGIRfiBRISC <br />MISS AECLANATIOY <br />August 20, 1996 <br />Bruce DeBrine <br />Division of Water Resources <br />1313 Sherman St., Room 818 <br />Denver, CO 80203 <br />Re: Howie No. 2 Mine <br />New Permit Application <br />Permit C-96-083 <br />Dear Mr. DeBrine: <br />'~~~ I~~II~~I~II~~'I~ <br />CIVIL ENGINEERIHC <br />CORSTRUCTION M7INAGENERT <br />RG~F1\(f=D <br />AUG 2 3 1996 <br />I~iviFiOn of M~nera+e ~ VE`olDyy <br />The Division of Water Resources' (DWR) letter dated August 9, 1996 <br />responds to BRL's letter dated August 5, 1996. One issue which <br />Chuck Roberts asked me to address to your attention was that of <br />drill hole sealing. <br />The DWR indicates there is a difference in drill hole sealing <br />requirements between the DWR and the DMG. BRL hereby requests a <br />variance from the DWR's Water Well Rule 15.2 regarding the sealing <br />of unconfined wells which states: <br />Unconfined Wells - Wells completed into unconfined aquifers <br />shall be plugged and sealed by filling with drill cuttings, <br />clean sand or clean gravel to the static water level, then <br />with clean native clays, cement or high solid bentonite grout <br />to the ground surface. A permanent watertight cover shall be <br />installed at the top of the casing. <br />BRL has two basic reasons for requesting the variance. The first <br />is the fact that some of the monitoring wells on the property <br />penetrate more than one water bearing zone. The DMG's rules <br />adequately address sealing multiple aquifer drill holes. The <br />second reason for this request is to simplify the regulatory <br />process. <br />BRL requests the following sealing technique be approved which is <br />quoted from DMG rule 4.07(2): <br />Exploration holes, drill holes or boreholes, wells, or other <br />underground openings completed in aquifers shall be sealed <br />using cement or other suitable sealant by placing the sealant <br />in the hole from the bottom to within 10 feet of the surface. <br />