Laserfiche WebLink
RUG-04-2003 MON 0327 PM BANKS AND GESSO LLC FAX N0. 303 274 8329 <br />design specifications for a French drain would result in any change that would <br />alter the proposed Reclamation Plan in any way. Regardless of the Divisions <br />findings on such matter, the end-use of the property will be water storage. While <br />we are not at all opposed to submitting design specifications to the Division for <br />review and approval and are agreeable to such a stipulation being added tc the <br />approval of this permit, we do not feel that a Technical Revision for review of said <br />design specifications is warranted. <br />Rule 6.4.7 Exhibit G -Water Information <br />4.. As with number three above, there is question as to why "further reporting in the <br />'form of a Technical Revision" will be required of the Applicant. Also as with <br />number three above, we do not feel that further reporting will create any change <br />that would "have more than a minor effect upon the approved or proposed <br />Reclamation Plan". Again, regardless of the outcome of further reporting on <br />groundwater to the Division, the end-use of the property will be water storege. <br />The only changes likely to result from any further reporting to the DMG on the <br />groundwater issue would be as to how mitigation to potentially injured parties <br />would occur. <br />5. We agree with the Division's assessment that defining of any trigger point for <br />mitigation should be withheld until further groundwater analysis, in the form of <br />implementation of the monitoring program outlined in WWE's second report, <br />gives us a clearer picture of the current groundwater conditions at the site. <br />With respect to the issue of defining a trigger point, we propose the following <br />stipulation be added to the approval of this permit (which was similarly and <br />successfully used in the approval of Permit M-2001-046 in May of 2001). The <br />Operator will implement the groundwater monitoring system as outlined in the <br />Wright Water Engineers, Inc. report, titled "Groundwater Monitoring and <br />Mitigation Plan for Heit Aggregate Resource Operation Wald County Aquatic and <br />Wetland Nursery and Coyle Property". At least 16 months of data will be <br />collected prior to initiating mining activities at the Heit Mine. Based on <br />observation of collected data, an augmentation trigger mechanism wilt be <br />proposed to DMG and approved by DMG prior to initiating mining activities. This <br />trigger mechanism should be specific as to volumes of water involved, times of <br />year for delivery, and length time augmentation will occur. <br />6. In review, we agree that cessation of de-watering activities within the slurry wall <br />will not likely result in the groundwater levels in the area of the aperetion to <br />rebound. We propose that mitigation during investigation of cause of injury <br />include transferring of dewatering water to affected parties. <br />7. If injury to surrounding groundwater users occurs as a result of the Heit <br />operation, the following mitigation plan will be implemented, as outlined in the <br />WWE Second Report. Mitigation Measure 5.1 will be implemented first. If this <br />option does not result in alleviated impacts, Mitigation Measure 5.2 will be <br />implemented. If this does not have desired results, Mitigation 5.3 will be <br />implemented, followed in order by 5.4 through 5.7, We believe that all of the <br />above measures, with the exception of 5.5 and 5.6, which are specific to AWC's <br />situation, could be implemented to mitigate impacts for all other parties <br /> <br />