2003-05-29_REVISION - M1999034 (2)

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_ . :_ f May 26, 2003 Division of Minerals and Geolog/ 1313 Sherman Street, Room 215 Denver, CO 80203 Attn. Larry D. Oehler Aggregate Iaduetries - QVCR, Inc. Amendment Nal-Jeroaimus Property Permit # M-99-034 Karen Topper ~ 8120 E. 104th Avenue Henderson, CO 80640 (303) 838-5636 RECEIVEp/ ~Ar Z r 200 Birisi0n ~f Minerals and GealO~y RE: Aggregate Industries - WRC, Inc. ,/~ Cooley Reservoir and Fukon Wildlife Area Amendment No. 1- Jeronimus Property Amendment to Permit No. M-99-034 ~ Dear Mr. Oehler: This correspondence is in reference to Aggregate Industries -WRC, Inc. (AI) regular (112) operation reclamation permit application amendment to existing permit M-99-034. I had previously registered my objections to the applicant's ameadmerlt application in a letter to your officc dated April 3, 2003. One of my concerns was the issue of ground water quality. I have recently contacted a representative with the Water Quality Contra} Division of the Colorado Department of Heahh and Environment to inquire as to the status ofthe applican's wastewater discharge permit. I was surprised to learn that the Water Quality Control Division issued a "genera]" wastewater discharge permit to Aggregate Industries with an effective date of October 1, 2002. "Generai" permits for process water and stormwater are not site specific. This type of permit does not address the reintroduction of existing adsorbed contaminants into the ground water environment. Unlike asite-specific discharge permit, requests for "general" permits do not have public ~tification or comment period. As such, the public was not afforded an opportunity to brirrgtireir concerns far~raid and tltc IYvisron dut notrevieww3tie "siCe=specific water quality ramifications of this proposed mining operation! Having specifically been told by the applicant's representative that the permit application documents I received were current, I am very disturbed wiry the applicant included an August 10, 1999 discharge pemut certification letter in Appendix D ofthe application rather than the new certifcation that was readily available: The current CDPS Industrial General Permit 110. COG-500000 has no requirements for ground water quality monitoring and has not been zeviewed for antidegradation. Ibring this issue to your attention as anther inconsistency in the permit application documents, and request that the Division of Minerals and Geology assure that the appropriate documents are submitted and that they meet the Division's rules and regulations.