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Submitted by: J. Mersch Ward <br />July 13, 2003 <br />¶ 2: The operator notes the plan to maintain concrete and asphalt production units on site. <br />These facilities will require storage for both cement and road oil along with fuel for the <br />mining equipment and heat for the asphalt plant. There is no discussion as to how these <br />facilities will be placed to insure that spillage or general operating activity does not <br />contaminate the ground water. An unlined central collection basin should not be <br />acceptable. <br />Reference is made to dry mining conditions. It is highly unlikely that such a situation will <br />exist. The mine is proposed in an azea known as the Spring Creek Bench. The geologic <br />section of this area, starting at the top, consist of a substantial "A" soil horizon that has an <br />adequate thickness for row crop agricultural production. This is followed by a "B & C" <br />horizon of varying thickness. Following the soil horizons is a substantial thickness of <br />gravel. On the mining site this gavel is reported to range from 20-60 feet in thickness. <br />The gravel lies unconformably on an impervious geologic unit known as the Mancos <br />formation that is made up of a thick sequence of marine shale. <br />Leakage from live streams, irrigation ditches, field irrigation and annual precipitation <br />passes through the soil horizons and into the gravel. The water continues to migrate to the <br />base of the gravel. It then moves in a northern and easterly direction along the <br />paleosurface of the graveUshale contact. The water is later picked up in shallow wells or <br />dischazged as springs along the eastern and northern toe of the mesa or dischazged as <br />make up water along the Uncompahgre River. These springs aze quite evident on slopes <br />along Mexican Gulch and its western tributary, which lies east of the mining property. <br />Wells and springs aze the water rights of others. The planned mine having an overall <br />length of a mile and width to one-quarter mile will intercept this aquifer and interfere <br />with these rights. The mine will also have to deal with the water as it enters the pit as well <br />as long-term reclamation at the bottom of the unfilled depression. Excessive water may <br />need to be dischazged, resulting in the need of a water dischazge pemut. These issues <br />need to be addressed. <br />¶3: Post-mined land use is proposed as cropland. It is uncleaz how a 3:1 slope will be <br />maintained as cropland considering the difficulty in planting, watering and harvesting <br />crops on such slope. It is also not understood what crops are to be maintained on the pit <br />floor with the possibility of a wet environment in part and the inability to drain off <br />excessive water from the pit floor when imgation is used. Long-term use does not appeaz <br />to be well thought out. <br />Minim Methods <br />¶ 1: The mine will not likely be a dry mine. See discussion above. <br />