2005-09-01_REVISION - M2000016 - Laserfiche WebLink

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M-2000-016, Lafarge West, Inc.: Riverbend Operation, AM-01 Adequacy Memo No. 6 September 6, 2005 Page 3 Because of the expected impacts and the well owners' concerns, a written agreement with the owner of Well Permit No. 12790 must be obtained prior to approval of this amendment. 5. Please provide a list identifying which monitoring wells will be monitored in association with each phase of the operation. 6. Include a statement in the Plan that, prior to mining each phase, the operator will submit to the Division the relevant five (5) quarters of baseline monitodng data and a notice regarding the earliest anticipated starting date for mining that phase. 7. During the August 12 meeting, the Division reiterated its concern for the protection of not only riparian vegetation, but also offsite vegetation, as noted in Item 15 of AR#4. In addition to establishing adequate monitoring, because the applicant's model predicts ground water drewdowns that will kill offsite cottonwoods, the applicant must propose proactive measures to protect the cottonwoods and offsite wetlands, such as, but not limited to, slurry walls or recharge trenches. 8. As noted in Item 24 of AR#4, the applicant must change the trigger points in the Plan for protection of offsite vegetation, including cottonwoods and wetlands. Please amend the Plan as requested. Regular inspection of offsite vegetation by a qualified individual must be incorporated into the Plan to monitor for signs of stress; therefore, the Plan must also identify sites to be inspected, as requested by Item 25 in AR#4. 9. Although some cottonwoods, such as those along Big Dry Creek, may be within permit boundaries and on the applicants property, unless the applicant obtains clearance from the U.S. Fish and Wildlife Service, the applicant needs to identify monitoring wells and mitigation measures incorporated into the Plan to protect these trees. 10. The Applegate Group response to Item 15 of AR#4 states that the applicant has "agreements already in place with potentially affected properly owners " Please submit copies of these agreements to the Division, clearly indicating which affected structures and/or vegetation they address. 11. Item 15 of AR#4 requested that the applicant identify all wells potentially affected by this operation (unregistered or otherwise unident~ed by the applicant) on the map and a table provided that lists the structure type and the name, address, and phone number of the structure owner. The list provided only included registered wells already identified on the maps. As requested in AR#4, please provide the specified information on unregistered wells that modeling indicates may see a greater than 2-feet drop in static water level. 12. As discussed at the August 12 meeting, the existing ditch agreement with Lupton Bottoms Ditch Company does not explicitly address potential increased water losses from the ditch as a result of this operation, nor does it cover the entire site for which the applicant is seeking this amendment, therefore it is inadequate for addressing Item 20 of AR#4. Also, the Division requires a Brighton Ditch agreement addressing this issue prior to amendment approval or the demonstration requested by Item 20, ARff4.