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M-2000-016, Lafarge West, Inc.: Riverbend Operation, AM-01 <br />Adequacy Memo #2 <br />April 22, 2005 <br />Page 4 <br />water, as applicable, of each cell when it is dewatered. The applicant needs to provide a <br />model and maps depicting these requested data. <br />13. (AMEC, p. 9) Please provide the basis for and explain the statements, "Ground water <br />flows into the pit and then leaves the system. In reality, it will probably be pumped into <br />the South Platte River, but the flow will not affect the water surface elevation in the South <br />Platte River and therefore will not affect the model results " <br />14. (AMEC, p. 11) Page 11 of the AMEC report indicates that registered alluvial wells within <br />600 feet were identified based on SEO records. Were field inspections conducted to <br />identify ALL wells within 600 feet? Will any wells beyond the 600-foot-radius be affected <br />by the mine operations? <br />15. (AMEC, pp.11-12) Regarding Well Permit No. 2216, the report concludes, "The <br />estimated drop in groundwater level at this well should have a minimal impact to the <br />historic use of the well." Table 5 shows that the modeled water level change at this well <br />during mining is -3.0 feet. What is the basis for this conclusion? <br />16. (AMEC, p. 12) The necessary agreement with the owner of Well Permit No. 13697, <br />which is expected to be unusable during the life of Phase 6 Cell 1, must be obtained prior <br />to approval of this amendment. <br />17. (AMEC p. 12) Well Permit No. 7280 was identified as within 600 feet, but opposite the <br />South Platte River from the mining activities, so not expected to be sign~cantly affected. <br />The Division agrees that impacts are not likely. However, to verify this assumption, the <br />applicant must install or identify a monitoring well in the vicinity of this well suitable for <br />establishing a baseline and monitoring for potential impacts. See also the Groundwater <br />Monitoring Plan section of this memo. <br />18. (AMEC p. 12) What were the criteria and how was it determined that "only one of these <br />wells [of the 4non-Lafarge wells within 600 feet] should not have the ability to pump at <br />historic rates?" The applicant must commit to specific criteria for establishing that "well <br />yields cannot be met and mining dewatering is determined to be the cause of reduced <br />well yield." The applicant must also state what measures will be taken to mitigate well <br />impacts, rather than provide a list of possibilities. <br />19. (AMEC, p. 14) The applicant must explain the statement, "Groundwater monitoring of <br />existing monitoring and production well water levels should be completed as mine <br />operations proceed." Additionally, the applicant must provide a plan to check calibration <br />of the ground water model by comparing predicted to actual drawdown in the monitoring <br />wells, and recalibrating the model as necessary. <br />20. Memo Item 12: Please provide documentation as to whether onsite wetlands and <br />potentially impacted wetlands offsite are considered jurisdictional wetlands by the US <br />Army Corps of Engineers. Absent of this documentation, all of these wetlands will be <br />assumed to be jurisdictional. <br />• 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 />• For any offsite wetlands, please describe how any impacts to wetlands will be <br />identified and the mitigation measures the applicant will take to minimize <br />disturbances to the hydrologic balance in relation to these wetlands. <br />