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GCC Rio Grande Pueblo Plant Via FedEx 799259009293 Tim Cazier Colorado Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman St. Room 215 Denver, Colorado 80203 R eceve o Division R 15 2013 Mlnin9 & Safety ty March 12, 2013 RE: Regular 112 Operations Mining Permit No. M- 2002 -004 GCC Rio Grande, Inc. — Pueblo Cement Plant and Limestone Quarry, Pueblo, Colorado Application for Technical Revision No. 3 (Modify Groundwater Monitoring Plan) Dear Mr. Cazier: GCC Rio Grande, Inc. (GCC) hereby requests the Division's approval of a technical revision to Mining Permit No. M- 2002 -004 for the Pueblo Cement Plant and Limestone Quarry (the Facility) in Pueblo, Colorado. The purpose of the requested revision is to modify the Facility's Ground Water Monitoring Plan as explained and discussed below. GCC's check in the amount of $216 is enclosed to cover the Technical Revision fee. GCC has conducted groundwater monitoring pursuant to Condition No. 1 of the referenced Permit since 2003. Over the years, GCC has installed six (6) groundwater monitoring wells at the Facility. MW -001 was located in the future limestone quarry and was plugged in April 2008. MW -001A was drilled into the Codel Sandstone, and has never produced enough water to sample. MW -002, MW -003 and MW -004 were drilled into the St. Charles alluvium. MW -005 was drilled in 2008 as an upgradient well, and also has never produced enough water to sample. Samples have been obtained from the alluvial wells, MW -002, MW -003 and MW -004, since 2003. In 2009, DRMS established numeric protection limits (NPL) for groundwater. In October 2011 total dissolved solids (TDS) in samples from MW -003 and MW -004 began exceeding the NPL. These exceedances coincided with lower- than - average rainfall amounts in the Pueblo area. At the request of DRMS, following the October 2012 sampling event, Contour Consulting Engineering prepared a Geologic Report demonstrating that the exceedances of the NPL could not be attributed to GCC's cement plant and limestone quarry and that, in fact, there is no direct hydrologic connection between the dry Colluvium underlying the Facility and the saturated Alluvium in which the wells have been completed. Based on this report, GCC proposes the following revised Groundwater Sampling Plan. Groundwater Sampling Plan GCC will properly plug and abandon MW -001A, MW -002, MW -003 and MW -004 in accordance with the provisions of Rule 16.2 of the State Engineer's Water Well Construction Rules. Documentation of "Well Abandonment" will be submitted to the Office of the State Engineer and DRMS. GCC will attempt to obtain groundwater samples from MW -005 twice per calendar year (semi - annually). If the well produces enough water to sample the samples will be analyzed for TDS, sulfates, RA -226 and RA- 228. By January 31 of the following year, GCC will submit a report to DRMS summarizing water level measurements and any analytical results obtained. GCC Rio Grande, Inc. • Pueblo Plant 3372 Lime Road • Pueblo, CO 81004 (719) 647 -6800 • Fax (719) 647 -6899