2005-01-11_REVISION - M1999120 (3)

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Kate Pickford Division of Minerals and Geology The other question -you requested submittal with this amendment, and not with a Technical Revision of baseline data and trigger points for the groundwater monitoring plan. We submitted preliminary pre-mining baseline data as part of the Groundwater Monitoring Plan that was included in the first adequacy response. We have collected 8 months of data thus far, and the 8- month average baseline data for each monitoring well is listed on Drawing 1, Shallow Groundwater Contours Near Ft. Lupton Operation. We will continue to collect data for at least 12 months, or until just prior to start of disturbance in amendment area, and the final pre-mining baseline averages will then be calculated from all data collected. We will submit the final pre-mining baseline averages to the DMG in the form of a Technical Revision. As far as trigger points, we propose that a change in the preliminary and then final baseline average monthly groundwater level in the vicinity of the amendment area of greater than 5 feet, and documentation of a complaint caused by this change, would trigger an investigation to confirm that L. G. Everist, Inc. (LGE) was responsible for the lowering of groundwater. If this investigation found that LGE was responsible, then LGE would work with the affected party to implement measures agreed to in order to resolve the complaint. Further, if there is a complaint prior to reaching the 5 foot trigger, it would be investigated to determine its causes, and if it is found that that LGE operations are responsible, then LGE would work with the affected party to implement measures agreed to in order to resolve the complaint. We are basing our proposed trigger point on the preliminary pre-mining baseline average data, which has shown natural fluctuations of groundwater levels of 3 feet. With this natural fluctuation, the trigger of 5 feet is actually reduced to 2 feet of change, an amount noted as acceptable to DMG. As mentioned above, the pre-mining baseline average groundwater level is based on data collected prior to disturbance in the amendment area. The post-mining average groundwater level will be based on a 12-month running average, less than a 12-month running average could be used for the first year. We hope that this additional information and commitments will ensure the DMG that all issues have been addressed, and that we are committed to being good operators and good neighbors. We formally request approval of this application, and if it cannot be granted at this time due to the time crunch, then we formally request an extension of the decision date, so that we can gather any additional information that may be needed for approval. Thank you. Sincerely, ~~ Lynn May Regulatory Manager cc: Ms. Maureen Jacoby, Banks and Gesso, LLC Mr. David Mehan, Wright Water Engineers Mr. Ross Bachofer Weld County Clerk to the Board's Office (for public review) LM/FL-DMGAdeq uacyResp2-010705. doc