Laserfiche WebLink
Appendix D. Comments from Rocky Mountain Consultants, /nc., Hydrokinetics, Inc., & Hydrodynamics,/nc. (Cont.) Page 13 <br />Conunenl: <br />8. Section lV.A.1 ~e 4. paragraph 5 <br />It is our understanding that TR-26 has not been fully approved by the OMG. Discussion ojarrd/ar incorporation by reference of <br />TR-26 in the permit should be restricted m those portions of TR-26 that have been approved by the DMG. Furhennore, because <br />this permit relies /teavily upon dte technical discussions provided in TR-26, the permit is incornp[ete wit/tout having the document <br />attached. <br />Moreover, TR-28 has not been approved nor has it passed the DMG's adequacy review. Consequently, TR-28 should not be <br />used as a basis for this permit. <br />Response: <br />7R-026 was formally approved in its enrrrery by the DMC on May 23, 2000. TR-028 has been xsthdraxm from consideration by <br />the DMG. Regardless, neither of these documents is incorporated by reference into Use latest version of the permit. <br />Comment: <br />9. Section IV.A. 1, vane 4. para~lt 6 <br />As-buihs of the french drain/sump system(s) must be provided to allow for an independent assessment of their effectiveness. <br />RMC pointed this out in its cormnent letter dated September l0, 1999, which was transmitted !o the CDPNE under cover of a <br />September 10, 1999 letter sent by Lori Potter regarding BMR!'s "Minimal Discharge /ndusMal Wastex~ater Permit <br />Application ". <br />Response: <br />As-built design information is not required to be subrnit[ed to the Division. The Division has no regulatory authariN to require <br />or review design injornration for industrial wastewater treaunent rystems. <br />Comment: <br />10. Table V-1. mare 6 <br />Atl pH data, field and laboratory, should be provided to suppor the statement that laboratory analyses tend to be less than the <br />field measured pH. <br />These data are only for Discharge Poin! 00/. Water quality data collected from the seeps and window area groundwater <br />monitoring wells should also be included and discussed in this section. <br />Response: <br />The perinent pH data are contained in the bi-weekly reports submitted by BMR/ to the Division under Amendment 1 of the <br />August 20, 1999 NOV/CDO. According to guidelines published by the U. S. EPA (Method 150.1) and the U. S. Geological <br />Survey (USGS, 2000; http:ll x~ater.usgs.gov/oxq/FieldManual/rnastererrota.hlrnl), pH should be measured in the field because of <br />the sensitivity of dre measurement to environmental conditions that inc[ude.• (I) ambient temperature, (2) concentration of carbon <br />dioxide, and (3) variations in pH values associated with instrument calibration (e. g., buffer solutions). Thus, the previous <br />statement regarding laboratory versus field pH determinations is not relevant to the discussion since compliance with pH <br />[irnilations is measured by the field awlyses. Previous seep and alluvial pumping x•e[l data is included in Appendix A. <br />Comment: <br />I1. Section V.B. yage 7, reference to NOV/CDOparagraplr 25 <br />Paragraph 25 of the August 20, 1999 NOV/CDO makes reference to "...the seeps into the Rito Seco, as described in paragraphs <br />13 and /4 above... ". Paragraph /3 of the NOV/CDO refers to one specific seep, while paragrap/t 14 oJthe NOV/CDO refers to <br />three other seeps. <br />As discussed in General Comment Na. 1, x~e recommend drat these specific seeps be designated as individual discharge points, <br />and regulated under the permit. Any other seeps w/rose raters originate from the West Pit should be considered unpermitted <br />discharges. <br />Response: <br />See response to Ceneral Comment No. 1. <br />