2003-05-27_REVISION - M1999034 (2)

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- ^";. z ° , May 26, 2003 / Division of Minerals and Geology/ 1313 Sherman Street, Room 215 Denver, CO 80203 Attn. Larry D. Oehler Aggregate Iaduatries - WCR, Inc. Amendment No.l - Jeronimus Property Permit # M-99-034 Karen Topper ~ 8120 E. 104t" Avenue Heudersou, CO 80640 (303) 838-5636 RECEIVED MAY 2 7 2003 / Birision ~f Minerals and GeolO~y RE: Aggregate Industries - WRC, Inc. ,/~ Cooley Reservoir and Fulton Wildlife Area Amendment No. 1- Jeronimus Property Amendment to Permit No. M-99-034 ~ Deaz 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 amendment application in a letter to your office dated Apri13, 2003. One of my concerns was the issue of ground water quality. I have recently contacted a representative with the Water Quality Control Division of the Colorado Department of Health and Environment to inquire as to the status of the applicant's wastewater dischazge permit. I was surprised to learn that the Water Quality Control Division issued a "general" wastewater dischazge permit to Aggregate Industries with an effective date of October 1, 2002. "General" 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 dischazge permit, requests for "general" permits do not have public notification or comment period. As such, the public was not afforded an opportunity to bring their concerns forward and the Division did not review the site-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 why the applicant included an August 10, 1999 dischazge permit certification letter in Appendix D of the application rather than the new certification that was readily available. The current CDPS Industrial General Permit No. COG-500000 has no requirements for ground water quality monitoring and has not been reviewed for antidegradation. I bring this issue to your attention as another inconsistency in the permit application documents, and request that the Division of Minerals and Geology assure that the appropriate documents aze submitted and that they meet the Division's rules and regulations.