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1atr. David Berry, CMLRD • <br />July 12, 1990 -page 2 <br /> <br />Derringer or Enfield pits. Trappers current plan is [o concentrate all utility ash in the <br />Ashmore pit area. If however ash disposal were to occur in either Derringer or Enfield pits <br />then the list D sample parameters would be adapted. However, at this time the list C para- <br />meters are more appropriate since no waste disposal is planned for these pis~apper <br />proposes to ieduce sampling from list D to list C in the following wells; GD2(( GD3 GFS, <br />GF6 an GFIl. <br />~2. Trapper concurs with the Division to continue the D list of parameters for wells GF4 and <br />GF7, as they are in the area of active ash disposal. <br />Lux Well <br />rapper concurs with the Division to continue the E list of parameters for the Lux well. <br />Section 2.9.2 - In order for Trapper to stay consistent with existing stream standards for the Yampa River, <br />iron and manganese will be analyzed for both total and dissolved analysis. In 1991, Trapper will <br />analyze surface water parameters [or "Dissolved" and "Total Recoverable" (Total recoverable will <br />/ replace samples currently analyzed by the total method) as recommended by the Division. Addi- <br />tionally, Permit table 4.8-12a "List of water quality parameters to be monitored, 1988-1992' is <br />updated to show [he analytical method associated with each parameter analysis. <br />Section 2.0 fMiscellaneousl <br />J Permit page 4-241b is updated showing the East Pyeatt monitoring location as an NPDES Moni- <br />toringsite. This page was previously updated with the Division approval of MR-82 (12-15-88). <br />Section 3.0 - Drainageway Reconstruction, Improvements and Repairs. <br />J Trapper will continue to monitor as-built configurations and channel stability to ensure proper <br />compliance with applicable state rules and regulations. As-built drainage profiles will no longer be <br />submitted as part of our Annual Report. Permit page 4-183b is updated to reflect this change. <br />Section 4.0 -Regraded Spoil Sampling <br />1. As approved by the Division, Trapper will only provide spoil sampling results associated <br />with regraded spoil sampling in Ashmore pit. However, Trapper will maintain accurate <br />records of all spoil areas on site and report to the Division problematic samples. <br />Please find an updated table 4.1 "Spoil Laboratory Analysis" from the CSU Soil Testing Laboratory. <br />Apparently you were sent a partial table without Selenium results. <br />J 2. Please find corrected table 2.7-2a. <br />S~ection~5.0 -Topsoil Stockpile Locations <br />/ The Division stated that Rule 2.05.3(5) requires all topsoil storage locations be approved prior to <br />development. It is Trappers contention the this is an unreasonable request. Due to the limited <br />access to many areas during the winter and spring months, it is very difficult to adequately locate the <br />most suitable areas for topsoil stockpiling before the program is initiated. This has resulted in a <br />number of minor revisions on Trapper part to ensure compliance with appropriate stale rules and <br />regulations. In response to the occasional construction of new (not previously approved) topsoil <br />stockpile at Trapper in the past years and the likelihood of future relocations to previously <br />approved sites, a statement allowing for the construction of additional topsoil stockpiles, not previ <br />