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RECEIVED Wilson Farms AUG 2 7 2002 9268 WCR 28 }~~~ Platteville, Colorado 80651 Oirisiott et Minerals and Geology Chris Gates 25 August 2002 Colorado Department of Public Health & Environment Division of Water Control 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 RE: Varra Companies Discharge Permit No: COG5000 Dear Mr. Gates, Attached is my letter transmitting well monitoring data to the DMG and Office of the State Engineer. If you want to review the raw data, I will forward it to you as well: Please let me know. The primary purpose of this letter is to again request that this permit not be renewed, at least not in its present form. We have reason to believe that the Operator is in violation of the groundwater discharge rate specified in the permit The permit states that the discharge flow mte is estimated to be an average of 0.72 MGD. A copy of the Permit is attached. My understanding is thaz this would equate to 500 gallons per minute (gpm). However, the Operator admits that the discharge rate is "approximately 1,500 gpm". (Note: Please see the 06/27/02 Inspection Report conducted by the Department of Minerals and Geology J We believe, from visual observations, that the discharge rate likely exceeds even the 1,500 gpm estimate cited by the Operator. We are not aware of a flow rate monitoring device that would ascertain the actual average flow rate experience for the Varra pit since exception. The DMG report leads us to believe that there is none. If none exists, we believe that this is an unacceptable condition. The Operator should be required to have an independently verifiable means of substantiating discharge rates. in the absence of such a monitoring device, the ability to monitor compliance is greatly diminished. More importantly, it becomes more difficult to prove off-site damage to wells. This is an additional burden that should not be placed on potentially injured parties. Therefore, if the Department chooses to renew the discharge permit in this we would urge that it do so only with the 500 gpm flow rate limit AND the requirement for placement qj' ~ monitoring device & flow nestricter(s) to ensure compliance on an ongoing basis. We continue to believe that the dry-mining & de-watering operation being conducted by Varra under Discharge Permit COG-50(10 is contributing to off-site damage in area wells. We are working to substantiate that claim with the DMG and the Office of the State Engineer While off-site damage to wells may not be a standard factor considered in renewal decisions, we want you to be fully appraised of our issues and ongoing attempts to address them with the appropriate governmental oversight agencies. We do believe, however, that these issues should bear directly on the conditions of the renewal in terms of the maximum discharge flow mte allowed, and the placement of verifiable monitoring meters to substantiaze compliance. Thank you. We ate certainly available to answer any questions raised by these requests. We also request that we be notified if the discharge perntit is renewed, and any conditions attached. Sincere ~• 'x~;/J 1~---~ W" "~- B and Bobbie Wilson CC: Kevin Rein, Otlice of the State Engineer Permit #: /~'J-~~c19 ~0U(e Confidental?: Class: Gruen rF1,c Type-Seq.: Carl Mount & Kate Pickford, DMG ) ~ To:~~ /~ From: ~nr,o /~ r San _ Doc. Name: ~3~s G~rG~/_ .'~~~1y-~ Doc. Date (if no date stdmp):