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~-FARG E <br />NCIRTH AMERICA <br />AGGREGATES, CONCRETE <br />Ei ASPHALT <br />determine the cause of the problem and. if necessary, implement measures to either restore the <br />we] 1's output or provide a temporary alternate supply of water to the owner. <br />18. (Ah1EC, p.12J What were the criteria and how was it determined that "only one of these wells [of <br />the 4non-Lafarge wells within 600 feet] should not have the ability to pump at historic rates?" <br />The applicant must commit to speciftc criteria for establishing that "well yields cannot be met <br />ana' mining dewatering is determined to be the cause of reduced well yield. "The applicant must <br />also state what measures will be taken to mitigate well impacts, rather than provide a list of <br />possibilities. <br />Lafarge has committed to specific measures to protect surrounding well owners for adverse <br />effects from the mining operafion in the Groundwater Monitoring Program previously submitted <br />to your office. The language in the Groundwater Monitoring Program simply suggests that there <br />are alternate means of remedying any effects on surrounding wells, and, as confirmed at our <br />recent meeting, Lafarge is not required to commit to one specific course of action. <br />1 R (AhfEC, p.14) The applicant must explain the statement, "Groundwater monitoring of existing <br />monitoring and production well water IE vels should be completed as mine operations proceed. " <br />Additionally, the applicant must provide a plan to check calibration of the ground water model <br />by comparing predicted to actual drawdown in the monitoring wells, and recalibrating the model <br />as necessary. <br />The primary purpose of the groundwater model is to predict the maximum extent of effects to the <br />prevailing hydrologic balance from the Honing operaton in order to determine locations where <br />monitoring wells should be located to protect sun-ounding property owners. The results of the <br />groindwater model show that the proposed groundwater monitoring plan will be sufficient to <br />identify adverse effects to surrounding wells or other structures in a proactive manner. If, for <br />example, a surrounding well shows signs of adverse effects resulting from the mining operation, <br />at that time the monitoring data can be used to determine if the adverse effects to the well are <br />linked to the mining operation. The grorndwater model could then be used at such a time to help <br />undclrstand how the mining operation may be influencing the effects on the well. The monitoring <br />data' can at that time be used to refine the model to develop a better understanding of how the <br />mining operation may be affecting the well. <br />We are not aware of any instances where the DMG has required operators of gravel pits to model <br />their operations on an ongoing basis. Only when the monitoring wells show that a surrounding <br />strucaure could be affected by the mining operation may an update to the groundwater model be <br />required, though this may not be necessary depending on the circumstances. <br />20. Menzo Item 12.• Please provide documentation as to whether onsite wetlands and potentially <br />impacted wetlands offsite are considered jurisdictional wetlands by the US Army Corps of <br />Engineers. Absent of this documentation, all of these wetlands will be assumed to be <br />jurisdictional. <br />o For all jurisdictional wetlands that will need to be replaced on site, the applicant must <br />submit a plan for replacing these wetlands so the Division can calculate the bond <br />necessary to implement the plan. <br />LAFARGE NORTH AMERICA INC. -Lafarge Construction Materials <br />10170 Church Ranch Way, Suite 200, Westminster, Colorado 80021 <br />Telephone: (303) 657-4000 Facsimile: (303) 657-4037 <br />