GENERAL32541

• Permit No: M2003037
• IBM Index Class Name: General Documents
• Doc Date: 3/17/2004
• Doc Name: Objection for Petition fpr Reconsideration
• From: DMG
• To: MLRB
• Media Type: D
• Archive: No

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~ STATE ~ COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
7313 Sherman St., Room 275
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
COLORADO
0[ V[ S[ O N O F
MINEgRALS
GEOLOGY
RECIAMATIO N•MI NING
EAEETY•s OENGE
Bill Owens
DATE: March 17, 2004 covemor
Russell George
TO: Mined Land Reclamation Board Executive Direcror
Ronald W. Cattany
FROM Pi
kf
K
d Division Director
: ate
c
or Natural Resource Trustee
RE: Objection for Petition for Reconsideration: Haldorson Sand and Grave!
Mine, Haldorson and Sons, Inc. File No. M-2003-037
The Division of Minerals and Geology (DMG) has reviewed the Objection for Petition for
Reconsideration related to the Haldorson Sand and Gravel Mine M-2003-037, and the attached report by
WestWater Associates Incorporated. The WestWater report contains numerous comments related to
various issues related to the site, This memo addresses only groundwater attd geologic issues raised in
the report.
The WestWater report questions whether the information submitted by Greg Lewicki and Associates
contains new information, thus justifying reconsideration by the Boazd. The Division has already stated
in a previous memo to the Boazd, dated February 26, 2004, that it believes that materials contained in the
Lewicki reports does, in fact, constitute new information.
The WestWater report questions the interpretation in the Lewicki reports that the dip of the Mancos shale
underlying the site is actually a structural feature. The WestWater report repeatedly states that the surface
orientation of the bedrock (Mancos Shale) at the location is a function of erosional features. Although the
Lewicki report does not confirm or deny whether the bedrock orientation is a result of structwal or
erosional effects on the bedrock, either situation should have little impact on the overall movement of
groundwater at the site. Although erosional features such as channels or islands may exist on the Mancos
surface, the overall slope or dip of the bedrock is to the northeast. Therefore groundwater will move in a
northeasterly direction along this surface.
In general, the sieve analyses and percolation tests reported in the Lewicki report indicate that the gravels
contained at the site will cause limited resistance to the movement of goundwater at the site. Regardless
of bedrock features and irrigation levels in the area, the permeability of the gravels will not change or be
affected by these pazameters. The analyses reported by Lewicki, indicate that the gravels do not cause
enough resistance to the flow of goundwater to allow it to build up and rise towazd the ground surface.
Additionally, the Lewicki report states that it was discovered that the site is assumed to be
hydrogeologically isolated from most of the rest of the mesa as a result of a barrier consisting of bedrock
that crops out along the southwest of the site. Therefore, the goundwater in question is essentially
limited to the irrigation water that is used only at the site itself.
The operator has further committed to cessation of mining in the quarter of the site if the weekly
monitoring of groundwater levels in the well for that quarter reach within 25 feet of ground surface.
CrFFce of Office of Colorado
Mined land Reclamation Active and Inattive Mines Geological Survey