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<br />may constitute a violation of the State Engineer's Office Rules. <br />For your information, I have enclosed a copy of the State Water Law <br />37-90-137 regarding the 600' rule. The State Engineer's Office <br />consider all dewatering areas to be a "well" and are permitted as <br />such. All gravel quarrys and mines that involve dewatering are <br />permitted as wells. If you wish to discuss this matter further <br />with the State Engineer's Office, please refer to Al Eckermann, <br />phone number 866-3740. I look forward to your response and <br />immediate attention to this matter. <br />Item 12: Thank you for your response. The Division requests a copy <br />of the ground water monitoring review report that is referred to on <br />page 6 of the April 1993 response, 2nd paragraph, 3rd sentence. In <br />addition, the Division requests an annual commitment to monitor the <br />total depth of wells, MW-8, 10 and 16. The current condition of <br />each of the three wells is ambiguous, since on June 28, 1993 during <br />the inspection it was mentioned in conversation that well MW-8 was <br />already undermined and was no longer of any use in monitoring <br />ground water data. Please clarify the condition of these three <br />wells in this response. <br />Items 13 through 17 are satisfied. Thank you for your Magpie Creek <br />diversion plans and thorough engineering studies. The Division <br />approves the Magpie Creek diversion plans as submitted. <br />Item 18: Satisfied in part, but Division copies do not include Map <br />13. Perhaps this was an oversight, please include Map 13 in your <br />response. <br />Items 19-21: Satisfied. Thank you for your response. <br />Item 22: Please refer to response #34. <br />Items 23 and 24: Item 23 satisfied. Item 24 seems to be a <br />misunderstanding: please indicate the current status of the 21 inch <br />culvert located at the lower end of Section A. Our field <br />discussion on August 11, 1993 indicated that this culvert was not <br />in place. Please clarify in writing. <br />Item 25: Do you wish to still make the certifications of pond as- <br />builts conditional upon Mid-term approval, as implied in your April <br />1993 response? If so, a stipulation will have to be added to your <br />permit pending as-built submittal. <br />Item 26: Thank you for your narrative response concerning the <br />Substation No. 1 and the explosives bunker. Substation No.2; small <br />area exemption approval on September 22, 1981 as referred to in <br />EFCI's response letter dated April 1993, is inadequate, due to <br />interpretations of Rule 4.05.2(3)(a) require demonstrations be made <br />for all SAE areas. Please provide a model demonstration that <br />surface water drainage off these areas will meet effluent standards <br />for the substation No.2 and the explosives bunker areas. <br />Suggested demonstrations include hydrologic model runs, silt <br />fencing the perimeter, commitment to sampling runoff and analysis <br />