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2. To determine if material damage may exist on the <br />White River AVF, the operator needs to submit an <br />impact statement regarding the saline discharge from <br />NPDES 024A. This determination and explanation must <br />then be inserted into the revised PHC. To assist <br />in making this determination, I suggest that the <br />operator acquire baseflow and water quality <br />information from the BLM on White River TDS levels <br />and graph this data from 1985 (date the Kenny <br />Reservoir was filled) to present. <br />3. Provide a map illustrating the location where the <br />water samples are taken for biomonitoring purposes. <br />4. That a graph of TDS levels be provided for Qal-5 and <br />NPDES 024 A in succeeding AHR's. <br />5. Provide a graph of mine inflow quantity in the AHR <br />B. REVISION OF THE PERMIT'S PROBABLE HYDROLOGICAL <br />CONSEQUENCES SECTION TO INCLUDE TDS DETERMINATIONS. <br />Nowhere in the permit, PHC or AHR's are there any Total <br />Dissolved Solids (TDS) determinations or predictions. <br />These determinations must be made and included as part of <br />the PHC. I recommend the following procedure: <br />1. That the PHC be revised to include TDS levels <br />that have been (past) and are currently being <br />observed in both the ground and surface waters. <br />2. TDS levels must also be predicted into a future <br />scenario using the past and current levels to make <br />a reasonable assumption. This information needs to <br />be incorporated into the revised PHC. <br />3. An explanation for the current TDS levels of 11,000 <br />mg/1 or more coming from NPDES 024A must be <br />explained and included into the PHC and AHR. <br />4. The current biomonitoring program with the CDOH <br />regarding elevated TDS levels of mine inflow waters <br />must be included in the revised PHC, mentioned in <br />the AHR's and followed closely in the future. <br />5. Increasing levels of both chloride and magnesium are <br />occurring in Qal-5 and need to be included and <br />explained in both the PHC and future AHRs. The <br />levels of both C1 and Mg are currently in violation <br />of recommended material damage suspect criteria. <br />