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Page 15 <br /> federal and Colorado laws. As stated above, the Division has determined that these <br /> requirements will be complied with by the operator. <br /> Comment: "...the City of Boulder does not believe it is appropriate to approve the proposed <br /> amendment to the existing reclamation plan for the Deepe Farm Pit until Western <br /> Mobile conducts a thorough evaluation of the potential ground water and irrigation <br /> system impacts for adjacent Open Space lands. Specifically, this evaluation should <br /> determine what affect the revision from 38.1 acres of surface water to 4.2 acres will <br /> have on ground water levels and irrigation flows within the adjacent Open Space lands. <br /> The City of Boulder wishes to ensure that the reductions in surface water which the <br /> proposed reclamation plan amendment incorporates do not result in adverse impacts to <br /> ground water levels and irrigation flows on the adjacent Open Space properties, <br /> threatening the habitat for Ute ladies' tresses orchid or the Preble's meadow jumping <br /> mouse." <br /> Response: The reclamation plan proposed in the amendment application includes a 1.9-acre <br /> groundwater-fed pond near the center of the permit area. There has been a groundwater- <br /> fed pond near this location for several decades. The size and shape of this pond has <br /> varied somewhat over time, depending on excavation and dewatering operations at the <br /> site. The proposed reclamation plan also includes a 2.3-acre groundwater-fed pond at <br /> the north end of the permit area. There is currently a pond at this location that has been <br /> created by relatively recent mining at the site (since 1988). Groundwater-fed ponds <br /> such as the two ponds at the Deepe Farm Pit create a slight cone of depression in the <br /> groundwater table. The effect of groundwater table depression caused by the existing <br /> ponds on the lands surrounding the permit area would be negligible. <br /> A quantitative analysis that forms the basis of the Division's opinions on groundwater <br /> table elevations is provided here. <br /> On December 7, 1989, the operator of the Deepe Farm Pit provided the Division with <br /> a report titled "HYDROGEOLOGIC IMPACT ANALYSIS OF DEWATERING <br /> FLATIRON SAND AND GRAVEL STAGE 4 AND 6 AT DEEPE PIT" prepared by <br /> Leonard Rice Consulting Water Engineers, Inc. The statement is made in that report <br /> that the hydraulic conductivity of the alluvial gravel mined at the Deepe Farm Pit ranges <br /> from 80-1200 gpd/fe and averages about 200 gpd/ft'. <br /> Using the average value for hydraulic conductivity,the capture zones for the dewatering <br /> trenches were analyzed and platted in the Leonard Rice report. These plats show that <br /> the capture zones extend no more than 260 feet from the deep dewatering trenches. The <br /> presence of only a 260-foot lateral extent for the groundwater capture zone during <br /> aggressive pit dewatering leads to the conclusion that the capture zone of evaporating <br /> groundwater lakes would cause only a slight cone of depression resulting in negligible <br /> impacts on the elevation of the ground water table. <br />