2007-04-13_REVISION - M1996008

• Permit No: M1996008
• IBM Index Class Name: Revision
• Doc Date: 4/13/2007
• Doc Name: Adequacy Review
• From: DRMS
• To: Greg Lewicki
• Type & Sequence: AM1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
7373 Sherman Si., Room 275
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
April 13, 2007
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APR 172dd7
Greg Lewicki Division of Reclamation
Greg Lewicki and Associates Mmfi9 and Safety
11541 Warrington Court
Parker, CO 80138
RE: Western Gravel, Inc., File No. M-1996-008
North R-34 Pit, 112(c) Amendment (AM-O1) Application- Adequacy Review
Dear Mr. Lewicki,
COLORADO
DIVISION OF
RECLAMAT[ON
MINING
- dc-
SAFETY
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
Listed below are adequacy review comments for the North R-34 Pit 112 (c) Amendment Application, File No. M-
1996-008. The Division of Minerals and Geology ("Division") is required to make a decision no later than April
19, 2007, therefore, your response to the following adequacy review concerns should be submitted to the Division
as soon as possible.
Rule 3.1.6 Water-General Reguirements
1. Section (1) of the General Water Requirements states, "Disturbances to the prevailing hydrologic balance of
the affected land and of the surrounding area and to the quantity or quality of water in surface and
groundwater systems both during and after the mining operation and during reclamation shall be
minimized..." The applicant has stated that the proposed activity at the site will likely cause a drawdown of
the groundwater table. The Applicant further states that there should be no impacts to wells as a result of the
dewatering as there are no wells in the area, according to Division of Water Resources records. Please supply
the distance of the closest groundwater wells to the site.
2. Also related to Section (1) please supply information related to the types of land use within one-quarter mile
of the site, specifically sites that maybe impacted by the removal of sub-irrigation, i.e. pasture, cottonwoods,
etc.
Rule 6.4.5 Exhibit E Reclamation Plan
3. Section (2) (c) requires the Applicant to provide a description of how the Reclamation Plan will be
implemented to meet each applicable requirement of Section 3.1. The Applicant has supplied this information
and has described the types of reclamation and post-mining land use proposed for various areas of the site.
The plan includes maintaining the cottonwoods that currently occur at the site, which the Division believes is
conducive to the proposed post-mining land use for that portion of the site, specifically wildlife habitat. The
Division is concerned, however, that despite the presence of the augmentation pond in the vicinity of the
cottonwoods, the groundwater may still be drawn down enough to negatively impact these trees. The
Division bases this concern on study results documented in a published USGS document titled "Responses of
Riparian Cottonwoods to Alluvial Water Table Declines," which concludes that a drop in the groundwater
table of one meter or more results in the mortality of cottonwoods. In that maintaining the cottonwoods is a
part of the reclamation plan, the Division believes that the groundwater elevation in the area of the
cottonwoods should be monitored. Please propose a method to monitor the groundwater level in the vicinity
Office of Office of
Mined Land Reclamation Active and Inactive Mines