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DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />June 25, 2012 <br />Mr. Toelle: <br />Mined Land Reclamation <br />Holcim US <br />Attn: Michael B. Toelle <br />3500 State Hwy 120 <br />Florence, CO 81226 <br />STATE OF COLORADO <br />RE: File No. M- 1977 -348; Boettcher Limestone Quarry; Requirement for Additional <br />Groundwater Characterization /Sampling. <br />The Division of Reclamation Mining and Safety (DRMS) has completed its review of the <br />groundwater monitoring analytical results reports for the March 2011 through March <br />2012 quarterly sampling events at the Boettcher Limestone Quarry site. Unfortunately, <br />it appears that some analytes have consistently exceeded the applicable MCL/benchmark <br />values. In particular, the levels of barium in MW3 and MW4, and TDS levels in MW4 <br />were consistently over the MCL/benchmark values. There were also consistent minor <br />exceedences of the MCL for boron in MW3. <br />As previously stated, if groundwater is shown to be impacted above applicable <br />benchmarks, additional monitoring, plume delineation, and perhaps remedial actions may <br />be required to release the site in accordance with 3.1.7 of the Construction Materials <br />Rule. Section 3.1.7(8) of the construction materials rule states that to achieve Release of <br />Reclamation Liability "An operator shall demonstrate, to the satisfaction of the Office, <br />that reclamation has been achieved so that existing and reasonably potential future uses <br />of groundwater are protected." To this end, the Division believes that further <br />characterization of the aquifer and current uses of groundwater in the area is required so <br />that Holcim and the Division can determine an appropriate path forward to the eventual <br />full release of the site. <br />The Division believes that, at a minimum, the following issues need to be addressed: <br />• What is the current extent of the impacted groundwater both vertically and <br />horizontally? Can it be shown that the impact is still confined to within <br />the permitted area? <br />• What specifically is the local geology? How might site geology influence <br />future migration of impacted groundwater, and how does it relate to <br />construction of the site monitoring wells and nearest surrounding /down- <br />gradient wells? <br />COLORADO <br />D I V I S I O N O F <br />RECLAMATION <br />MINING <br />— &— <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta Piiieda <br />Director <br />Office of Office of <br />Denver • Grand Junction • Durango Active and Inactive Mines <br />