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Preliminary Adequacy Issues 6 April 25, 2008 <br />AM-03, M-1988-112 <br />from the West Pit. Please demonstrate that any leakage through the geomembrane of the <br />irrigation storage ponds will not escape the. capture zone of the West Pit dewatering wells. <br />Please expand the laboratory testing and ground water modeling to address the issues raised <br />by Mr. Bird. <br />Adequacy Issues Specific to Rule 6.4.12 <br />As noted above, the Division considers the plans proposed through AM-03 to be experimental in <br />nature. Therefore, please ensure that Exhibit L addresses maintenance costs of the water <br />treatment plant necessary to keep the plant intact and ready for immediate reactivation. <br />Please ensure that Exhibit L addresses the cost of a remediation plan to include the <br />construction and operation of capture wells and infrastructure necessary to remove potentially <br />contaminated ground water down gradient of the irrigated lands and return and treat the <br />captured ground water at the treatment plant. <br />The Division understands that the Applicant is pursuing approval through the process of the <br />Office of the State Engineer for the water rights issues related to the activities proposed in AM- <br />03. Please affirm that construction of the irrigation storage ponds and irrigation pipeline will not <br />commence until the Applicant secures all necessary approvals through the Office of the State <br />Engineer and water court. In the absence of such affirmative statement, please ensure that <br />Exhibit L addresses all reclamation costs associated with removal of the irrigation storage ponds <br />and irrigation pipeline. <br />Under section L.4.3 of AM-03, the Applicant assumes that pumping of the West Pit will only be <br />required for 50 years and that pump replacement will be required not more than once every 20 <br />years. Please support the 50-year and 20-year assumptions. The Division understands that the <br />plans proposed through AM-03 are for a perpetual water management program and not limited <br />to a period of 50 years. <br />Given the assumption that equipment will fail, over time and need replacement, please ensure <br />that Exhibit L includes costs for periodic repairs and replacement of the irrigation storage ponds, <br />irrigation pipeline, center pivot irrigation equipment, and all monitoring and point of compliance <br />wells associated with the perpetual water management program. <br />Adequacy Issues Specific to Rule 6.4.13 <br />Please discuss the potential for a land application permit through the Colorado Department of <br />Public Health and Environment (CDPHE), Water Quality Control Division (WQCD), which may <br />ultimately permit the irrigation activity and satisfy the requirement of Rule 3.1.7(8). In addition, <br />please discuss the potential for a permit from the Hazardous Materials Waste Management <br />Division (HMWMD) of CDPHE regarding the proposed pipeline and impoundment pit: <br />