HomeMy WebLinkAbout20123524.tiff ASPHALT
SPECIALTIES CO .
10100 Dallas St. • Henderson, CO 80640 • (303)289-8555 • Fax: (303)289-7707
December 7, 2012
Mr. Eric Scott
Environmental Protection Specialist
Colorado Div. of Reclamation, Mining and Safety
1313 Sherman Street, Room 215
Denver, Colorado 80203
RE: Responses to Second Adequacy Review for Amendment(AM-2), Turnpike Mining
Resource,DRMS Permit No. M-2004-009
Dear Mr. Scott:
We (ASCl/Weiland, Inc.) are submitting our responses and information to you regarding
your second adequacy review comments received by us via e-mail on October 17, 2012.
We have asked for and you have approved three extension requests in order to for us to
properly answer primarily your concerns with groundwater issues on the referenced
permit site.
Enclosed are:
1. Revised map Exhibits C-2 and F, the mine and reclamation plan maps.
The only change on the mine plan maps are additional utilities and revised
locations all enclosed within the easement for the Erie/ASCI utilities on
the east side of the entrance road. Since the utilities are all contained
within an easement, there is no change to the mining limits with this
update. After further review of the backfilling of the "trout pond" in the
northwest corner of the permit area that is a reclaimed feature of the old
DMG permit on this site,we have realized that there is not enough backfill
material (shale, overburden)to fill this pond at this time. It is all accounted
for in the current mass balance figuring for the reclamation of'the current
mining activities. As stated before, the augmentation for this pond will be
accounted for in the revised SWSP plan that will be renewed upon
approval of this amendment. ASCI does own ditch shares in the Boulder-
White Rock Ditch that serves this property and will use those shares as
part of a permanent augmentation plan for this pond. Since we are not
backfilling the trout pond, there is no revision to Exhibit L with his
adequacy submittal. The revised Exhibit L submitted on October 18, 2012
is still valid.
2. Structure Agreement letters and attachments (agreement and map) for the
three remaining structure owners within 200 ft. of the mining limits of this
site in the southernmost area of the permit (previously sent by e-mail to
�j���� you). Until such a time that these agreement letters are signed by the
thel ctC 2012-3524
affected parties or that a geotechnical stability analysis is performed that
states that the mining and reclamation activities on the Turnpike mine site
will not adversely affect any offsite structures, ASCI commits to mining
no closer than 200 ft. flout any identified structure in the agreement letters
on file with the DRMS.
3. Finally, the groundwater report and specifications for a monitoring
program for both quality and potential offsite mounding. The map figure
can be printed at 11" x 17" for better clarity. It should be noted that the
method of backfilling the shale into the mined-out sand and gravel in the
currently active area of the permit will be accomplished with the pit in a
de-watered state and that substantial compaction will occur to the shale
due the weight of heavy equipment used to fill the material.
Peter Wayland has mailed a complete set of signed original mine and reclamation plan
maps to you and they should be there by Monday. I will be mailing a package of these
materials up to the Weld County Clerk to the Board today and she should have this
information on Monday as well. I will also place original materials (minus the maps) in
the mail to you today.
We feel that, especially the groundwater monitoring program, this response is complete
in every manner and that we have satisfactorily answered your second set of adequacy
concerns regarding this amendment to the Turnpike Mining Resource. We look forward
to your timely approval of the amendment so that we can start in with the requirements of
the amendment.
Please contact either me or Peter Wayland if there are any questions or concerns you may
have and thank you for your attention to this matter.
Sincerely,
Rob Laird
Land Manager
cc: file
Dan Hunt
Peter Wayland
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YYl Weiland, Inc.
Environmental& Engineering
WATER QUALITY AND GROUNDWATER
MOUNDING/SHADOWING PLAN
TURNPIKE MINING RESOURCE
M-2004-009-AM-2
Prepared by:
Weiland, Inc
PO Box 18087
Boulder, CO 80308
Prepared for
Asphalt Specialties Co., Inc
10100 Dallas St
Henderson, CO 80640-8491
December 7, 2012
PO BOX 18087 . BOULDER, CO 80308
ph 303-443-8521
1.0 WATER QUALITY 1
1.1 Background 1
1.2 Map 1
1.3 Method of Monitoring Well Completion 1
1.4 Method of Sampling, Frequency of Sampling and Reporting to the Office; 1
1.5 Parameters Analyzed, Water Quality Analysis Methods, and Quality
Control/Quality Assurance Methods; 2
1.6 Formations, Aquifers or Strata to be Sampled; 2
1.7 Potential Sources of Groundwater Contamination that will be monitored by
Each Point of Compliance Monitoring Point; 2
1.8 Time-Schedule for Implementation 2
1.9 Ambient Groundwater Quality Data Sufficient to Characterize Potentially
Impacted Groundwater Quality 3
2.0 GROUNDWATER MOUNDING / SHADOWING 4
2.1 Background 4
2.2 Historic/Baseline Groundwater Levels / Mounding Analysis 4
Figures
Figure 1 - Site Plan - Groundwater
Figure 2 - Typical Monitor Well Completion
Appendices
Appendix A - Summary of Labatory Classification/Moisture Density Relationship
Appendix B - Water Quality Sampling Parameters
1.0 WATER QUALITY
1.1 BACKGROUND
The reclamation plan calls for the placement of shale backfill material into Cell 2.
The shale backfill material was previously excavated from the pit floor of Cell 1.
Due to the low permeability of the shale backfill material, it is possible that up-
gradient groundwater levels could increase (mounding) and down-gradient
groundwater levels could decrease (shadow). For the purpose of evaluating the
extent of mounding/shadowing, installation of observation and monitoring wells
shall be completed as discussed below.
The DRMS had commented that there is the possibility of impacts to groundwater
quality due to the backfilling of shale material within the alluvial aquifer. Impacts
to groundwater are predicted to be unlikely due to the very low permeability of
the backfilled shale material. The shale backfill material is classified as lean clay
with a plasticity index of 22 as determined by a geotechnical analysis of the same
shale bedrock material which was used to construct the reservoir liner in Cell 1
(see Appendix A). The backfilling process will likely result in compaction to 80-
90% of maximum dry density, which combined with the high clay content, will
yield very low permeability as achieved by the weight of and compaction by
heavy equipment placing the material. This plan will however, gather ambient
water quality data and, in the event that water is in fact observed to flow through
the backfilled shale, a water quality sampling program has been specified. In
order to determine if any groundwater flow occurs through the backfilled shale
material, observation wells shall be constructed within the backfilled shale area.
In accordance with Section 3.1.7(b) of the Construction Materials Rule, the
following information is provided concerning groundwater monitoring:
1.2 MAP
The map given in Figure 1 accurately locates all proposed groundwater sample
points (monitor wells) and observation wells.
1.3 METHOD OF MONITORING WELL COMPLETION
Monitor wells (MW-1, MW-2) shall be completed at the locations shown in Figure
1. Wells shall be completed to the depth of bedrock and screened within the sand
and gravel layer. A typical well completion diagram is given in Figure 2.
Observation wells shall be completed within 2ft of the bottom of the shale backfill
area at locations shown in Figure 1. Observation wells may be constructed of
plain PVC pipe with a 5 ft screen interval at the bottom of the string. The annulus
may be backfilled with onsite sand and followed by 2ft of shale for a surface plug.
Observation wells are designed for water level measurement and not water
quality sampling.
1.4 METHOD OF SAMPLING, FREQUENCY OF SAMPLING AND
REPORTING TO THE OFFICE;
Rule 3.1.7 (4) b states "If there is a reasonable potential to exceed groundwater
quality standards promulgated by the WQCC, the Operator shall modify the
Page 1 of 6
permit as necessary to implement such standards in compliance with this
Subsection, 3.1.7". For the purpose of determining if a "reasonable potential"
exists for the backfilled shale material to impact water quality through leaching of
inorganic minerals to groundwater, analysis of groundwater flow through the
backfilled shale shall be performed. Observation wells OW-3 through OW-5 are
designed to determine if groundwater occurs and or is flowing through the
backfilled area.
Water levels in observation wells OW-3 through OW-5 shall be measured,
recorded and be reported bi-monthly for 90 days following the completion of the
reclamation backfilling of Cell 2 (A,B,C).
If no water is found in observation wells OW-3 through OW-5, then no water is
flowing through the backfilled material and therefore there would be no
reasonable potential for the backfilled material to cause impacts to water quality.
If observation wells OW-3 through OW-5 yield a saturated layer within the
backfilled shale, then water sampling from MW-1 and MW-2 shall be performed
and reported quarterly for aperiod of 1year. The water sampling p sa piing parameters are
given in Appendix B, which are based on Colorado Regulation No. 41: The Basic
Standards for Groundwater(5 CCR 1002-41) (WQCC 2009).
1.5 PARAMETERS ANALYZED, WATER QUALITY ANALYSIS METHODS,
AND QUALITY CONTROL/QUALITY ASSURANCE METHODS;
Groundwater samples shall be analyzed for the parameters given in Appendix B,
which is taken from the Colorado Regulation No. 41: The Basic Standards for
Groundwater, Table 2 — Inorganic parameters for domestic water supply.
1.6 FORMATIONS, AQUIFERS OR STRATA TO BE SAMPLED;
The aquifer to be sampled is the tributary alluvial aquifer composed of sand and
gravel.
1.7 POTENTIAL SOURCES OF GROUNDWATER CONTAMINATION THAT
WILL BE MONITORED BY EACH POINT OF COMPLIANCE
MONITORING POINT;
The potential source of groundwater contamination is the backfilled shale
material. MW-2 will be constructed just down-gradient of any groundwater flow
that may be transmitted through the backfilled shale.
1.8 TIME-SCHEDULE FOR IMPLEMENTATION
Monitor wells 1-2 shall be constructed and ambient water quality will be sampled
before the end of 2012 or early 2013. If necessary, MW-2 will be sampled
quarterly for one year following the backfilling of Cell 2. Observation wells OW-1
and OW-2 shall be constructed before the end of 2012 or early 2013 and
observation wells OW-3 through OW-5 shall be constructed following the
completion of backfilling Cell 2.
Page 2 of 6
1.9 AMBIENT GROUNDWATER QUALITY DATA SUFFICIENT TO
CHARACTERIZE POTENTIALLY IMPACTED GROUNDWATER
QUALITY.
As indicated above, ambient groundwater data will be gathered following
completion of the monitor wells.
Page 3 of 6
2.0 GROUNDWATER MOUNDING /SHADOWING
2.1 BACKGROUND
Due to the low permeability of the backfilled shale material, it is possible that up-
gradient groundwater levels may rise to levels that could impact adjoining
property owners to the east. The Schell house occurs approximately 250ft up-
gradient of the backfill boundary and the Timmreck house occurs approximately
183ft up-gradient of the backfill boundary. The Andreason domestic well occurs
west of the Cell 2C backfill area, however is unlikely to be affected by a
groundwater shadow since the groundwater flow vector is northwest (See Figure
1). Currently, pumping is occurring in Cell 2A and therefore establishment of
baseline water levels cannot be achieved by measuring the monitoring well
presently or in the near future at this location. Instead, this plan will piece
together some historic and published data to approximate baseline water levels.
2.2 HISTORIC/BASELINE GROUNDWATER LEVELS / MOUNDING
ANALYSIS
Previously, a portion of Cell 2 A had been allowed to fill with groundwater due to
shutdown of the pumps. On July 14, 2012 the water level of the pond in Cell 2 A
was surveyed at 4938.32ft. July would normally be considered a time when the
seasonal groundwater levels would be expected to be near their maximum. This
is due to the fact that the local groundwater levels are strongly influenced by
regional irrigation and stages of the local ditches. Irrigation ditch diversions in
the area typically peak in July and tail off in August-Oct. It should be noted
however, that the summer of 2012 was considered a drought year. Additional
baseline groundwater levels were measured during a subsurface investigation
that was conducted by Rocky Mountain Consultants (RMC) in October 1999.
Elevations are given in Table 1.
For the purpose of estimating historic seasonal high groundwater levels, the July
2012 pond water level in Cell 2 A ("July Pond") is used to back calculate up-
gradient water levels based on the published regional water table gradient given
in the USGS Open File Report 02-338. The eastern edge of the July Pond in
Cell 2 A occurred 675 ft down-gradient from the observation well on Schell's
property (108A). Multiplying that distance by a gradient of 0.0031 ft/ft (USGS
OFR 02-338) and adding to the July Pond elevation, yields a water level of
4940.41ft. This elevation compares reasonably well with the observed October
2011 water level of 4938.51 ft. at well 108A considering that October
groundwater levels would be expected to be a few feet lower than July. The
October 1999 RMC test hole TH-39 occurs 202.55 ft up-gradient of the July
Pond. Multiplying that distance by a gradient of 0.0031 ft/ft (USGS OFR 02-338)
and adding to the July Pond elevation yields a water level of 4938.95 ft. This
elevation compares reasonably well with the observed October 1999 water level
of 4937.5 ft (+1.44 ft difference) of TH-39 considering that October groundwater
levels would be expected to be a few feet lower than July.
Page 4 of 6
The observation well at 108A occurs at approximately the same up-gradient
distance from the Schell house and therefore will serve as a good well to observe
the influence of the clay backfill material on groundwater levels. It is estimated
that the elevation of the lower footing at the Schell house is at 4944.0 ft. The
threshold not to exceed groundwater elevation value at well 108A is therefore set
at 4944.0 ft. The value of 4944.0 ft is 3.6 ft above the predicted seasonal high
water table elevation at 108A. At a minimum, water levels at MW-1 and 108A
shall be observed and recorded monthly for one year following the backfilling of
Cell 1. A more detailed water level measurement schedule will be prepared and
submitted to the DRMS before any more significant backfilling of Cell 2 occurs.
If water levels are observed to exceed 4944.0 ft at 108A, then ASCI shall be
required to design and build an engineered groundwater level mitigation system
that will alleviate high groundwater levels on the Schell property to levels below
4944.0 ft at observation well 108A. Alternatively, ASCI will reserve the right to
cause groundwater levels higher than 4944.0 ft on the condition that a signed
notarized agreement between ASCI and Schell or Schell's successors that would
allow them to do so.
Table 1. Observed Groundwater Elevations
Site Date Elevation
Cell 2 A July Pond July 2012 4938.32
TH-39 Oct 1999 4937.5
Schell 108a Oct 2011 4938.51
TH-44 Oct 1999 4942.0
In order to estimate the seasonal high groundwater elevation in the vicinity of the
Timmreck house, the October 1999 observed water level at TH-44 is adjusted by
1.44 ft from 4942.0 ft to 4943.44. This adjustment is based on the predicted July
elevation for TH-39 based on the discussion above. The distance from TH-44 to
the Timmreck house is 493.52 ft. Multiplying that distance by a gradient of 0.0031
ft/ft (USGS OFR 02-338) and adding to the adjusted TH-44 elevation yields a
water level of 4944.96 ft. The finished floor elevation of the Timmreck house
appears to be 4956.2 ft, which would put the bottom of the footing at
approximately 4954.0 ft.
The proposed observation well OW-1 occurs 146 ft down-gradient from the
Timmreck house. Multiplying that distance by a gradient of 0.0031 ft/ft (USGS
OFR 02-338) and subtracting from 4954.0 ft elevation yields a water level of
4953.54 ft. The threshold not to exceed groundwater elevation value at well OW-
1 is therefore set at 4953.5 ft. This is approximately 8.5 ft above the predicted
seasonal high groundwater elevation described above. At a minimum, water
levels at OW-1 shall be observed and recorded monthly for one year following
the backfilling of Cell 1. A more detailed water level measurement schedule will
be prepared and submitted to the DRMS before any more significant backfilling
Page 5 of 6
of Cell 2 occurs. If water levels are observed to exceed 4953.5 ft at OW-1, then
ASCI shall be required to design and build an engineered groundwater level
mitigation system that will alleviate high groundwater levels on the Timmreck
property to levels below 4954 ft or 4953.5 at OW-1. Alternatively, ASCI will
reserve the right to cause groundwater levels higher than 4953.5 ft on the
condition that a signed notarized agreement between ASCI and Timmreck or
Timmreck's successors that would allow them to do so.
Page 6 of 6
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HOLE NUMBER DATE LOGGED BY DRILLER NOTES
D / 5�P�&Pei, /V / /4., a e��
- CLAYEY SAND AND
-3 - - - SILT. LIGHT TAN TO / --3
-4 - SC/CL - - OF CLAYWN. . LAYERS /I _
o
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CE COBBLES DIRTY, _ --14
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18� -,--r,^� ,_-.-.7 Y Y. f C_ _ Ds i= R --18
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m_ __21
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- - --23
24 SHALE - HALE,BEDROCK,
za
- CLAY,- AY. BLUE GREY -
-25- _ - __25
_ _
--26
_ _ _-2J
-27
FIGURE 2 Weiland. Inc_ TYPICAL MONITOR WELL COMPLETION
Environmental&Engineering
APPENDIX A
•
Earth Engineering Consultants, Inc.
Summary of Laboratory Classification/Moisture-Density Relationship
145 - Material Designation: 1082030.0
Sample Location: Boring No.9-1.0'-9.0'(Bedrock)
. ..\\\ Description: Claystone/Siltstone Bedrock(Classified as LEAN
CLAY)
140
Atterbra Limits(ASTM D-4318)
- - Liquid Limit: 37
135 Plastic Limit: 15
- • I Plasticity Index: 22
._. . Percent Passing No.200 Sieve(ASTM C-117): 98.2%
130 Standard Proctor(ASTM D-6981
Maximum Dry Density: 114.0 pcf
c Optimum Moisture Content:: 15.0%
u. 125 - '
v Curves for 100%Saturation
120 For Specific Gravity Equal to:
2.80
2.70
a 115 2.60
0 110 -
Q
105 •
100 I ,
95 r : T
90 •
0 5 10 15 20 25 30 35
Percent Moisture
Project: Turnpike Reservoir A
Erie,Colorado
Project No: 1082030
Date Apr-08 - -
APPENDIX B
Water Quality Sampling Parameters (Rule 41 for Domestic Water Supply)
Inorganic Water Quality Parameters . Standard
Antimony(Sb)°,M 0.006 mg/I
Asbestos M 7,000,000 fibers/Liter
Arsenic(As)°•M 0.01 mg/I
Barium(Ba)°,M 2.0 mg/I
Beryllium(Be)°'M 0.004 mg/I
Cadmium(Cd)°'M 0.005 mg/I
Chromium (Cr)Q°,M 0.1 m9/I
Cyanide[Free](CN)M 0.2 mg/I
Fluoride(F)°'M 4.0 mg/I
Lead(Pb)d 0.05 mg/I
Mercury(inorganic)(Hg)d'M 0.002 mg/I
Molybdenum (Mo)° 0.035 mg/I
Nickel(Ni)° 0.1 mg/I
Nitrate(NO3 )° M 10.0 mg/I as N
Nitrite(NO 2 ) M 1.0 mg/I as N
Total Nitrate+Nitrite(NO 2 +NO 3-N)°,` 10.0 mg/I as N
Selenium (Se)°'M 0.05 mg/I
Silver(Ag)d 0.05 mg/I
Page 1 of 2
Water Quality Sampling Parameters (Rule 41 for Domestic Water Supply)
Thallium (TI)tl•M 0.002 mg/I
Uranium (U)d,M 0.03 mg/I
Page2of2
AFFIDAVIT OF RECEIPT
State of Colorado
County of Weld
BEFORE ME, a repre entative of the Weld County Board of County Commissioners, on
this 11 day of Jfl,yytbeA( , 20 ;I did receive a copy of the Second
Adequacy Review Comments letter, revised Exhibit Maps and a Groundwater Report for
DRMS Turnpike Mining Resource Amendment No. 2 for public display.
RECEIVED
Weld County Clerk to e Board
COUNTY
WELD ignature
COM M1SSiONERS
Name (printe
f\ ed:261)1-Q-Baird
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