Laserfiche WebLink
ROCKY MOUNTAIN CONSULTANTS, INC., HYDROKINETICS, INC., AND <br />HYDRODYNAMICS, INC. <br />Responses to comments provided by Rocky Mountain Consultants, Inc. and others aze <br />presented in the following pages. The comments and responses aze indexed according to <br />the format of the original document. <br />GENERAL COMMENTS <br />Comment: <br />1. Short-term West Pit Groundwater Discharee Issues <br />The permit correctly points out on page 7 that the statute, 25-8-501(1), CRS provides <br />that: <br />"No person shall dischazge any pollutants into any state <br />water from a point source without first having obtained a <br />permit from the division for such dischazge." <br />Note that "State water" is defined in 25-8-103(9) to include "any and all surface <br />and subsurface waters which are contained in or flow in or through this state...." <br />Cleazly discharge to subsurface waters, or groundwater, is regulated through the <br />statute. <br />The Technical Support Document for the CDPS Permit Application, dated 30 <br />Aug. 1999, indicates on page 3: <br />"Groundwater flowing through the West Pit exits the pit <br />through a restricted zone where the backfill material <br />contacts the Rito Seco Alluvium (the "window"). <br />Groundwater from the west pit then co-mingles with Rito <br />Seco alluvial groundwater and a portion of the mixed <br />groundwater emanates as surface seeps adjacent to the <br />Rito Seco in the immediate vicinity of the window." <br />This confirms that only a portion of the groundwater flowing from the west pit <br />emanates as surface seepage, the remainder continuing to migrate through the <br />Rito Seco alluvial aquifer systems without definition of quantity, quality, or fate. <br />The permit rationale indicates in the second full paragraph on page 12 that: <br />""The heterogeneity of the alluvium and the variability <br />of the groundwater flow in the alluvium and the Rito <br />Seco are such that there are no discrete locations at <br />which a numeric effluent limitation can be measured. <br />In addition, the system is characterized by a diffuse and <br />Bank Mwnlain Resources, lnc. HS/ GeaTrans <br />~] July 2l, 1000 <br />