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Corey Heaps <br />CAM - Colorado, LLC <br />November 30, 2010 <br />Page 23 <br />91. There is no discussion of groundwater points of compliance for the proposed project. <br />Please review your ground water monitoring program specific to establishing a <br />groundwater point (or points) of compliance at the Fruita Loadout, and specify which well <br />or wells will be available as point of compliance well(s) for the alluvial groundwater. The <br />PAP should address the need for points of compliance and be updated accordingly. <br />92. Under the surface water analysis of page 2.05 -52, there is no discussion of the amount of <br />discharge from the sediment ponds. A value of 100 gallons per minute is given in the table <br />of parameters on page 2.05 -52 but it is unclear how this was calculated. It appears that <br />Pond 4 is the only pond designed to passively discharge and the remainder of the ponds <br />will be dewatered by pumping. How was the 100 gallons per minute calculated and does <br />this account for all five ponds? Please revise the surface water discussion in the PHC to <br />include these details on estimated outflow from each of the sediment ponds. <br />93. There is no discussion of the Colorado River in the PHC. CAM is proposing to divert <br />water from Loma Drain and Reed Wash and there are proposed discharges to Reed Wash. <br />Since the site is in close proximity to the Colorado River and both Loma Drain and Reed <br />Wash ultimately drain to the river there should be some conclusion and quantification of <br />impacts (if any) added to the PHC discussion for the Colorado River. <br />94. In the Probable Hydrologic Consequences Section 2.05.6(3)(b)(iii) on permit text pages <br />2.05 -49 and 2.05 -50, it is stated that surface water is unlikely to recharge the alluvial <br />ground water system and some general assumptions are provided. Please add specific <br />information to the discussion that supports this assertion. <br />95. In Section 2.05.6(3)(b)(iv) on permit text page 2.05 -58, it is stated that water monitoring <br />records will be maintained on site and submitted to the Division annually. Please add that <br />the discharge monitoring reports for the NPDES permit will be submitted to the Division <br />on a quarterly basis, as required in Rule 4.13(2)(a)(iii). <br />96. In Table 2 — Surface Water, on page 2.05 -57 of Section 2.05.6(3)(b)(iv), CAM lists the <br />analytes that will be monitored as part of the surface water monitoring plan. The table <br />indicates that all listed metal constituents will be analyzed as total metal constituents. <br />CDPHE receiving stream standards, however, require the analysis of metal constituents as <br />dissolved and/or total recoverable metals; depending on the metal constituent and stream <br />segment (the exception to this is mercury, which is always analyzed as a total constituent). <br />The analysis of a metal constituent using the total metals methodology will, necessarily, <br />yield an equal or higher concentration than the analysis of a metal constituent using the <br />dissolved or total recoverable methodology. The use of a total metals methodology in <br />baseline analyses will, generally, yield higher concentrations of metals, the results of which <br />are not comparable to receiving stream standards. PIease change the analytical method for <br />the metals analyses to either dissolved or total recoverable (or both) as necessary in Table <br />2. If, however, CAM believes that the analytical method should remain as total metals, <br />