2004-08-05_REVISION - M2000158 - Laserfiche WebLink

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With the elimination of recharge structures, the Operator is not proposing to take adequate measures to minimize impacts the prevailing hydrologic balance of the azea surrounding the affected land, as required in section 3.1.6 of the Construction Materials Rules and Regulations. Failure to install rechazge structures could result in impacts to adjacent wells and cottonwoods trees. If rechazge structures aze to be eliminated in the mine plan, the Operator must identify a specific monitoring plan for the site or a specific mitigation plan for the site including trigger points that would prompt mitigation measures (for both wells and cottonwood trees). A monitoring plan and mitigation plan, specifically outlining monitoring frequencies and mifigation measures that will be incorporated, needs to be submitted with the pernut application and must be approved by the Division prior to approval of the permit. 3. The Division received comments from the Division of Wildlife (DOW) regazding the AM-Ol Application. The letter is attached for reference. Please further describe how the cottonwood trees and wetland habitat in proximity to Shazkey's Lake and Longhorn Lake will be protected without a dewatering trench as initially proposed. As stated above, if recharge structures aze to be eliminated in the mine plan, the Operator must identify a specific monitoring plan for the site or a specific mitigation plan for the site including trigger points that would prompt mitigation measures (for both wells and cottonwood trees). A monitoring plan and mitigation plan, specifically outlining monitoring -frequencies an~tigation measures tha~vn"1 a mcotpora a ,nee to e su mrttecfwith the pernnit application and must be approved by the Division prior to approval of the permit. 4. Stipulation No. 2 of the permit states: "The Applicant will prepare and submit to the Division for its approval a complete design for the construction f any recharge structure by no later than August 1, 2001... " Such information was submitted to the Division on August 8, 2001 by Leonard Rice Engineers, Inc. Attached is a copy of the letter and the map. Please be aware that in addition to the recharge structure, the applicant committed to a water level monitoring program. Please state how this water level monitoring program will be revised to take into account the lining of Shazkey and Longhom Lakes. 5. Platte Sand & Gravel states that new wells that were installed by the oil companies after the permit was issued in 2001 'uut prior to filing of this A1~I-Ol should not have to meet the requirements of Rule 6.4.19 and Section 34-32.5-115(4)(e), C.R.S. regarding maintain a mining off set distance of 200 feet of any structure or demonstrate that mining will not affect such structures. According to Rule 1.10(4), Applications for amendments shall be reviewed by the Boazd or Office in the same manner as applications for new Permits. The rules and statutes do not exclude structures that were constructed between the time a permit was issued and the filing of an amendment. It is also Division policy that amendments to applications must address new structures on site, or within 200 feet. Therefore, please address the following issue that was noted in the Division's Adequacy Letter of July 8, 2004: During the pre-operation inspection of July 7, 2004, it was noted that 12 new welts and associated gas/oil lines have been constructed since issuance of the permit in 2001. The applicant must maintain a mining off set distance of 200 feet of any structure or demonstrate that mining will not affect the structures. If agreements are forged with 2