HYDRO26598

• Permit No: M1980244
• IBM Index Class Name: Hydrology
• Doc Date: 4/28/1995
• Doc Name: COMMENTS CRESSON LOW VOLUME SOLUTION COLLECTION PERMIT M-80-244
• From: DMG
• To: BERHAN KEFFELEW
• Media Type: D
• Archive: No

• • III IIIIIIIIIIIII III
999
STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman SL, Roam 215
Denver, Colorado 80203
Phone: [phone]
FA%: 13031 832-8106
DATE: APRIL 28, 1995
T0: Berhan Keffelew
FROM: Jim Pendleton
RE: Comments

II~~~
DEPARTMENT OF
NATURAL
RESOURCES
ROy Romer
Governor
lames S Lochhead
Eaecuiive Director
Michael B. LOng
Low Volume Solution CollectioA.ion Direcbr
M-80-244)
I reviewed the data reports you had loaned me concerning the CRESSON leakage into
the I~aak collection system beneath the saturated pond while flying back from
Kentucky. The data appears relatively complete, with the exception of the elevation of
the Actual saturated solution level. We need the saturated level to judge compliance
with CRESSON's response plan and acceptable leakage rates. The increased and
stabilized (25 ppm) CN concentrations suggest that the initial entrained slug of
metE~oric water has been purged from the collection layer. We will need to require
future reports include the saturated pool elevation. Further, as I discussed during my
participation through the conference call, we will need a tabulated detailed rendition of
the ~~aturated areas corresponding to each saturated pool elevation, and the
acceptable leakage rates corresponding to figures 4.1 and 4.2 in the amendment 6
application. Once we are in possession of all of this information we will be able to
properly judge compliance with CRESSON's approved plan. If we do not receive this
information by the last day of May, 1995, I will propose to Bruce Humphries and Mike
Long that we issue an administrative violation to CC&VG, because their failure to
provide sufficient information may impede our ability to properly regulate.
It's rlow becoming obvious that CC&VG is preparing to suggest that it's permit
doesn't say what it intended. John believes the leak collection head maintained at
below 2 feet should suffice, regardless of the leakage rate through the primary liher.
NOT! We should require an Amendment if they want to "clarify" this point. I can't
wait to hear Roger...
cc: Mike Long
Bruce Humphries
Doc: M:/MIN/JAP/CRESSON.LCS
JP/jp