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Page 4 <br />Pueblo East Pit adequacy responses <br />M-1986-015 <br />Item 5 - Rule 3.1.6 - (summary) Questions regarding minimization of disturbances to the prevailing hydrologic <br />balance. <br />Response: The response to this item must be divided into three sections. It is a complex matter and <br />several actions have been taken to address this issue. <br />Groundwater Monitoring - Included is a report prepared by Bishop-Brogden Associates that <br />describes the groundwater monitoring program that has been established. This program is already in place and <br />monthly data is taken from all the wells. This prob*ram provides a means to monitor the background groundwater <br />levels and fluctuations as• well as detect effects from the pit dewatering. Note that some of the monitoring wells are <br />rather far Erom the pit location. These are not expected to be affected by Phase 1 of the operation and therefore <br />provide a measure of what the normal groundwater is doing. The wells closer to the pit can provide information on <br />the effects of dewatering. This monitoring not onl y shows what the effects on dte groundwater are, but also acts as <br />an early warning system to alert adjacent well owners when problems might be starting to happen. That early <br />warning system also allows the company to correct negative effects on adjacent wells before those effects become <br />serious. <br />Although not included in dais adequacy response, a complete model of the groundwater in this• area has been <br />developed to estimate what effects the pit might have on nearby wells. That model, of course, is not based on actual <br />monitoring data but on other, more standardized approaches to modeling groundwater. The monitoring program, <br />however, can provide a correction factor for the model. In time, the model can be fine tuned using actual data from <br />the site. Thus prediction of impacts on adjacent wells can be more easily made and with greater accuracy. A copy of <br />that model report is available if you desire to have it. <br />Commitments to Nearby Well Owners - In anticipation of possible adverse effects on adjacent <br />well owners, as determined by the groundwater model, agreements were sought from well owners within 200 feet of <br />the affected land. Enclosed are the signed agreements with those parties showing that Transit Mix of Pueblo will <br />correct any problems- that occur. This correction not only goes to water production, but the physical integrity of the <br />well if the operation were to cause it to collapse. Please note, that in the process- of applying for a well permit for the <br />gravel pit, the State Engineer requires that all well owners widnin 600 Eeet of the permit location be notified and <br />provided an opportunity to comment or object. This was done. Only one party objected and that is the subject of the <br />next section of this response. <br />With respect to one well, the Prijatel well, there were severe problems in locating anyone who would claim <br />ownership of the well A letter From Mark Klune is included that describes all the effort he went to in finding an <br />owner. There are also a couple of photographs that show the well is not in use. In the well house there is an old, <br />rusted surge rank. The pump had been removed for quite some rime. It appears this well is in fact abandoned even <br />though it is still listed as a well. <br />Resolartion of the Detta Helmsing Objection - Although an agreement existed between <br />Helmsing and Valco regarding her well, Ms. Helmsing was not satisfied that it actually protected her. 'T'herefore, she <br />filed the objection. Through negotiations and a hearing with the State Engineer's oEFce, an agreement was reached <br />that was satisfactory to Ms. Helmsing A copy of the signed agreement is- included. <br />Item 6 - Exhibit ll -Slurry Wal] Construction - (summary) Request for as-built drawings after constmction of the <br />slurry wall. <br />Response: It is agreed that as-built drawings of die slurry wall will be provided. As is the case with the <br />Pueblo West Pit where similar walls are to be installed, the construction plans are being submitted to the State <br />Engineer for approval prior to construction. That will undoubtedly be required here xs well. These plans and <br />approvals, as well as tests' of wall integrity, will be provided when the time comes to implement that step. <br />