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2015-03-20_HYDROLOGY - M1977493
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2015-03-20_HYDROLOGY - M1977493
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Last modified
8/24/2016 5:58:33 PM
Creation date
3/27/2015 3:45:28 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977493
IBM Index Class Name
HYDROLOGY
Doc Date
3/20/2015
Doc Name
Proposed NPL Comment Letter
From
Leonard Rice Enginerrs, Inc
To
DRMS
Email Name
ECS
Media Type
D
Archive
No
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LeonardRice <br />ENGINEERS,INC. <br />Integrated Water Resources Engineering <br />Innovative Solutions for Water and Land <br />(a) Pursuant to the procedures specified in Paragraph 3.1.7(3), permit or NOI <br />conditions shall be established for each operation that may have a reasonable <br />potential to adversely affect the quality of a specified area that has not been classified <br />by the WQCC. Such permit or NOI conditions may be in the form of numeric protection <br />levels, practice -based permit or NOI conditions, or both. <br />(b) Points of compliance for numeric protection levels shall be set pursuant to <br />Paragraph 3.1.7(5). <br />(c) Permit or NOI conditions, whether practice -based or numeric protection levels, <br />shall be established as follows: (i) The permit or N01 conditions shall be protective of <br />the existing and reasonably_ potential future uses of the groundwater that maybe <br />affected The WQCC'sgroundwater quality table values (The Basic Standards For <br />Ground Water CCR 1002 -41), shall be used as a guide in establishing the permit or NOI <br />conditions. (ii) Where ambient groundwater quality exceeds values for protection of <br />existing and reasonably potential future uses ofgroundwater, such as groundwater <br />table values or other numeric criteria, permit or N01 conditions shall be established to <br />protect those uses against further lowering ofgroundwater quality. <br />(DBMS Hard Rock Rule 3.1.7(2), emphasis added) <br />Although the table values are intended as a guide, it is the obligation of the DRMS to implement <br />protections for all existing and reasonably potential future uses of the groundwater that may be <br />affected, which includes use for surface water, a use that currently occurs in the Eagle River <br />drainage. <br />WQCC Regulation No. 41 recognizes surface water quality protection as a classified use, and the <br />DRMS, as an implementing agency, plays a critical role in providing that protection. <br />Ground water within a specified area shall be classified 'Surface Water Quality Protection" <br />when: A proposed or existing activity does or will impact ground waters such that water <br />quality standards of classified surface water bodies within the specified area will be exceeded. <br />(Reg. 41.4.13.3) <br />In its actions for groundwater impacted by Rocky Flats, the WQCC adopted surface water quality <br />standards for groundwater in order to protect adjacent surface waterbodies. The WQCC, in its <br />decision on applying surface water standards to groundwater, determined that <br />It is appropriate to apply the surface water quality standards... to the shallow aquifers at <br />Rocky Flats because they contribute water to those streams which the Commission recently <br />protected with more stringent standards (Regulation No. 42.10, 1991 SOBP for Rocky Flats <br />site) <br />
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