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RE: L. G. Everist, Inc„ Fort Lupton Sand and Gravel Mine, DMG #M-1999-120; <br />Second Adequacy Response Letter <br />12. Wetlands east of CR25 <br />The "wetland" on the East of CR25 appears to presently be connected to the East Lateral, and <br />presumably, occasionally receives water from the Lateral. The "wetland" may also at one time <br />have received surface water from the west -there used to be another Lupton Bottom Ditch <br />lateral located to the south and west. Therefore, this "wetland" is sustained by surface water <br />from two possible sources -the East Lateral, and any remaining surface connections to the <br />west, not by groundwater from the south. <br />LGE did some additional field work prior to the January 19`" meeting and in the meeting noted <br />that there is a large drainage ditch -which conveys water from Sand Hills Reservoir and <br />possibly also seepage from the land around it -that travels along the north side of CR18, is <br />about 10 feet deep, and will intercept shallow groundwater from the south side of CR18. The <br />possible buffering effects of this ditch were not included in the model. <br />Although factors would indicate that this "wetland" is fed by surface water and not by <br />groundwater from the south, LGE already has a monitoring well in place on the south side of <br />this wetland, and will be monitoring on a monthly basis. If the groundwater levels change <br />enough to reach the trigger point, then LGE will start an assessment, and if responsible, will <br />implement necessary mitigation measures. <br />In addition to the monthly well monitoring, LGE will observe the "wetland" (or cottonwoods, see <br />#13 and #14) to document pre-mining conditions, and then after slurry wall construction begins <br />to assess any impacts. This pre-mining monitoring will include numeration of wetland species, <br />percent cover of wetland species, and extent of upland weeds (or numeration of numeration of <br />dead cottonwood trees, and observations of leaf desiccation, see #13 and #14). The "wetland" <br />(or cottonwoods, see #13 and #14) will be observed in early July, and also early September (if <br />slurry wall construction has not begun) for pre-mining conditions. Photographs will be taken <br />from established photo points. Also, as discussed in the meeting, the "wetland" (or cottonwoods, <br />see #13 and #14) will be visually monitored, and the monitoring well checked, on a weekly basis <br />from the start of construction of a slurry wall until 1 month after completion of a slurry wall, in <br />order to observe if there are any impacts. If observations indicate impacts from LGE operations, <br />LGE will make an assessment, and if found responsible, will implement appropriate mitigation <br />measures with the permission of any affected property owners. Please see #4 for a list of <br />mitigation measures. If observations indicate no impacts, monitoring will go back to monthly <br />monitoring of the well, and vegetation observations before and after the installation of each new <br />slurry wall. <br />13. Cottonwoods north of CR18 along the South Platte River <br />WWE and LGE believe the groundwater level beneath the cottonwood grove northeast of the <br />expansion will be maintained by shallow groundwater from the South Platte River, which is <br />immediately adjacent to the trees, and by water in the large drainage ditch (noted above in #12) <br />that conveys water from Sand Hills Reservoir and runoff through the grove. Aerial photos show <br />that water from the river backs up into the ditch as it bisects the grove (this can be seen on <br />Drawing 5, included in the Groundwater Monitoring report from the first adequacy response). <br />We are familiar with the USGS study on effects of alluvial water table declines on cottonwoods <br />that DGM cited. This study found mortality to increase in a threshold response to water table <br />declines of > 1 meter. The modeling completed by WWE showed a maximum water table <br />decline of around one meter in a portion of the grove. However, the model did not include <br />LM/FL-Resp2ndAtlegRev-dmgKP-012105.doc 6 <br />