Laserfiche WebLink
Appendis D, Comments front Rocky Mountain Consultants, /nc., Hydrokinetics, /nc, & Hydrodynamics,Inc. (Cont.) Page IS <br />Comment: <br />/7. Section V/.A.2. pa~founh full para~h. last sentence <br />As discussed in Comment Number 8, the permit is incomplete without having the TR-26 (and TR-28) documents attached. And, <br />because TR-28 has not been approved nor passed the DMG's adequacy review, it should nor be used as a basis for this permit. <br />Response: <br />See previous response to Cotmnent Number 8. <br />Comment: <br />I8. Section V/. A. 2. page 12. laslparagroeh <br />Monitoring data collected as pan of the Wes! Pit rnpnitoring .system should be provided on a more routine basis than the annual <br />requirement specified in this section. An annual repon slrou[rl still be required, but more frequent reporting (i. e., monthly) of <br />surface water and groundwater rnoniloring data is certainly x~arranted. <br />Response: <br />The COPS permit has been revised so that there is no longer an annual repon requirement. /nstead, as pan of [he COPS <br />permit, BMR/ will be required to submit the results of the performance monitoring prpgrarn for both surface water data and <br />groundwater data at a monthly basis to the WQCD. <br />The DMG receives monthly reports of the water quality data collected as pan oJlhe TR-026 performance monitoring program. <br />Thus, the data are available and pan ojthe public record. The groundwater level elevation data from the backfilled Wesr Pit <br />constitutes the most pertinent injonrratiorr that measures the status of 1/re rystern. Groundwater level injonnation is also <br />communicated to the DMC on a morsthly basis. This data will also be submitted ro the WQCD. <br />Comment: <br />/9. Section VI.A.3. ~e /3, mass balance anal, <br />The mass balance analysis ignores any loading to the surface water system from the seepage front. T/re permit mus! account for <br />loading Jrom the seepage front or explicitly smte that there is zero allowable discharge from the window to the Rito Seco and its <br />alluvium. Otherxase, the [Hass balance analysis underpredicts the total loading from West Pir to the Rito Seco system which, it <br />turn, allows for a greater loading jrorn Discharge Point 00/. <br />Response: <br />The mass balance assumes tha! !here is and xdl! be no discharge from 002. The permit x¢!l require BMR/ tp continue to <br />eliminate the flow of groundwater jrorn the Wert Pit info the adjacent Rito Seco alluvial aquifer. As noted previously, the <br />hydraulic gradient has been reversed such drat there is no [Hass loading to the Rito Seco jrorn the seepage front because t/te flow <br />ojgrottndwater jrorn the West Pit has been eliminated. /Jin the future, there are discharges from 002, this is addressed under <br />the compliance schedule. !J routine discharges should occur from 002 in !!te future (however, no discharge from this outfall is <br />erpecred), the mass balance equations would need to 6e reevaluated. <br />Comment: <br />20. Section V/.A.4.c. ~e 14, cable <br />The acute and chronic Q values are reversed (compare to Section 1/I.B.2). The QJ data presented in [Iris table are also <br />incorrect. /s this error propagated throughout the entire repon? <br />Q, only includes flow derived Jrom Discharge Point 00/. See Cotmnent Number /9 regarding rlte inclusion ojseepage front in a <br />complete analysis of the impact of West Pit discharge on the Rito Seco system. <br />Response: <br />The headings for this table related to acute and c/rronic flow values /rave been corrected. The Q values used throughout the <br />calculations are correct. <br />See the response to Comment Number /9. <br />