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Erica Crosby <br />Division of Minerals and Geology <br />Page 2 of 3 <br />November 1, 2004 <br />(including measured strikes and dips by the USGS) along with borehole logs of nearby bedrock <br />water wells from the Division of Water Resources, State Engineers Office. The attached base <br />map and cross section A-A' indicate that A-pit water may be a suitable monitoring/compliance <br />point but this finding in not conclusive. <br />The water surface elevation in A-pit is 14 feet lower than the water surface elevation in C-pit as <br />of October 18, 2004. A-pit water is topographically downgradient of C-pit water. C-pit was <br />mined to recover the Fort Hays Limestone while A-pit was mined to recover the Smokey Hill <br />Shale (both are members of the Niobrara Formation). The Smokey Hill Shale overlies the Fort <br />Hays Limestone. If C-pit water was entering the Fort Hays Limestone it would be difficult to <br />imagine water moving up the stratigraphic column given the minimal hydraulic head. Some <br />Smokey Hill Shale is exposed in C-pit (removed as overburden to get to the limestone) and <br />these beds of Smokey Hill Shale may connect to the bottom of A-pit however this is not known <br />(the bedding in the vicinity of C-pit and A-pit dips approximately 6°-8° east-southeast). <br />Due to the uncertainty about the degree of hydraulic connection between C-pit and A-pit, <br />Cemex is proposing to install two new ground water monitoring wells located as shown on the <br />base map. The wells will be screened in the Fort Hays Limestone and are proposed to be used <br />as monitoring and compliance points. <br />The off-site well completed in the Dakota Formation (which is not owned or controlled by <br />Cemex) will continue to be monitored by Cemex but will not be designated as either a <br />monitoring or compliance point. Neither Cemex nor the Division want a permit condition that <br />cannot be assessed without the permission of a third party not bound by the DMG's regulations. <br />The following summarizes proposed monitoring and compliance points: <br />C-pit water -Source (C-pit is neither a monitoring nor a compliance <br />point) <br />A-pit water -Surface water monitoring point <br />New monitoring well -Downgradient monitoring point <br />New compliance well -Downgradient compliance point <br />Off-site Dakota Formation well -Regional groundwater quality indicator <br />In previous discussions with the Division, Cemex proposed monitoring St. Vrain Creek and the <br />Boulder Feeder Canal water to establish some baseline water quality data. This is no longer <br />deemed necessary because of the plans proposed herein. <br />Cemex will submit a ground water mitigation plan to the Division if an exceedance of any of the <br />five water quality parameters are observed in three consecutive monitoring events. The plan <br />will be submitted to the Division within 30 days of the trigger event. The plan will identify the <br />source(s) of the exceedance and the proposed remedy to comply with the applicable standards. <br />