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The LRE letter suggests that inflow data are not available to quantify the relationship between <br /> surface water and groundwater recharge to EPR. Climax has examined information related to <br /> aquifer properties, basin area,precipitation, and reservoir storage records (all of which are available <br /> to LRE either publically or through Climax reports shared with EPRC)to evaluate potential <br /> groundwater recharge to EPR, relative to surface water recharge. This evaluation indicates that <br /> groundwater recharge, on an annual basis, represents less than 0.4%of the overall storage volume <br /> of EPR, and on the order of approximately 1% of the average annual total reservoir recharge. <br /> The LRE letter also suggests that the proposed NPLs based on the WQMP indicator parameter list <br /> may not be appropriate. In compliance with the WQMP,which should be noted was reviewed and <br /> not challenged by LRE and EPRC, Climax has been providing EPRC with all water quality <br /> monitoring data collected in accordance with the plan. LRE also was provided with historical data <br /> for the area during their review of TR-18. These data(to be included in a revised WQMP) show <br /> that the indicator parameter list can be reduced based on the data observed over time. <br /> LRE's reference to the 1998 Purchase Agreement for EPR relates to a subject outside the purview <br /> of DRMS. Therefore, it is not appropriate for DRMS to become engaged in a debate over the <br /> meaning of an agreement between two private entities. <br /> Climax is preparing a revised EPP with updated WQMP to be submitted to DRMS as TR-25. The <br /> revised WQMP will include a new appendix describing the development of NPLs and <br /> demonstrating compliance with DRMS Regulations, which cite to the WQCC interim narrative <br /> standards. In the spirit of continued cooperation with its neighbors, Climax intends to share the <br /> draft WQMP with EPRC for review and comment prior to submittal to DRMS. Also, attached to <br /> this letter is a technical memo by Tetra Tech with a mass balance mixing model that was developed <br /> to evaluate the loading of potential chemical constituents to EPR if groundwater quality equaled the <br /> NPLs to be included in the revised WQMP. The results of the model show that concentrations of <br /> indicator parameters in EPR will remain at levels well below surface water quality standards (i.e., <br /> no exceedance of surface water standards), further demonstrating that the Climax NPLs protect <br /> water quality in EPR. <br /> We request that you add this letter to the DRMS administrative file for Permit No. M-1977-493. <br /> Thank you for considering our comments and please contact me if you have any questions regarding <br /> this letter and attachment. <br /> Sincerely, <br /> Raymond Lazuk <br /> Environmental Manager <br /> attachment <br /> c: Linn Brooks, Eagle Park Reservoir Company <br /> 3 <br />