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es c J ~l ~,d,ti, ~~%~-~`- <br />IVIL RES"~URCES, LLC <br />ENGINEERS 5 PLANNERS <br />May 9, 2006 <br />REDEI'~/ED <br />~(AY f 2 20~ <br />Ms. Erica Crosby <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />r/di~iga ei Mi„pa,,,yd <br />RE: Hall•Irwin Corporation, Application No. M•2006.003 <br />ParkerlDersham Sand and Gravel Resource; May 8, 2006 Groundwater Model Review <br />Dear Ms. Crosby: <br />Following is our response to your Adequacy Review dated May 8, 2006, Groundwater Model Review, °Parker- <br />Dersham Gravel Mine', Hall-Irwin Corporation File M-2006-003, Class: Permit <br />1. The applicant must commit to a groundwater level monitoring program with monthly water level <br />measurements at the six (6) existing piezometers throughout the life of the operation, or until such <br />time that the Division determines that the monitoring schedule of groundwater levels at the Parker <br />Dersham Gravel Mine may be revised or is no longer needed. <br />Hall-Irwin commits to monitor groundwater levels monthly at the six existing piezometers throughout the life <br />of the mine, or until such time that the Division determines that the monitoring schedule of groundwater <br />levels at the Parker-Dersham Gravel Mine maybe revised or is no longer needed. Hall-Irwin will submit <br />this information to the Division with their annual report or upon request. If groundwater levels drop below <br />the trigger level the Division will be notified. <br />2. The applicant must commit to an action level or "trigger" that will prompt the need for mitigation <br />measures to be implemented. (The Division suggests that the applicant consider a trigger of 3' <br />beyond the observed baseline groundwater elevation, as the natural seasonal fluctuation at most <br />piezometers appears to be 2'). <br />The applicant will'commit to a trigger response in the event the mining phase of the operation causes a <br />drawdown of three feet or greater. The miner will first install a temporary piezometer near the neighboring <br />well and water level readings will betaken everyday for one week to determine if the water level reading is <br />accurate (unless it is observed that immediate action is necessary). Surrounding groundwater stresses <br />(other mines dewatering, farmers running pumps) will be taken into account during this week observation <br />period. The average observed water level and the surrounding stresses will than be used to determine the <br />correct mitigation measures per the Section 4.2.1 in the Groundwater Study. <br />3. The applicant must specify provisions for reporting of action levels encountered during mining as <br />well as the reporting of annual water monitoring data and summary results to the Division. The <br />applicant may also want to specify measuring criteria to be used to verify that a true exceedance of <br />an action level has occurred. <br />451 OAK STREET, SUITE 209 • FREDERICK, COLORADO 80530 • PHONE: 303.833.1416 • FAX: 303.833.2850 <br />