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14. On permit text pages 2.05-18 and 2.05-19 in Section 2.05.3(4)(a)(ii)(C), please describe where <br />the excess sediment from the pond cleanings will be disposed. <br />15. As stated on permit text page 2.05-20 in Section 2.05.3(4)(d), the Division has to make a <br />finding that runoff from disturbances within 100 feet of Reed Wash will comply with Rule <br />4.05.18. If sediment ponds 3 and 4 are eliminated and best management practices are employed <br />through a revision of the sediment control system for the rail loop, please revise permit text <br />page 2.05-20 to show how the requirements of Rule 4.05.18 will be met. If silt fence is used, <br />the Division requests that Sedcad designs for silt fence be provided for those stream buffer <br />zone areas in order to demonstrate compliance with the stream buffer zone rule. The Division <br />will make the findings once the sediment control system designs have become final. <br />16. If CAM elects to revise the sediment control system and eliminate most of the sediment ponds <br />for the railroad loop and, instead, uses best management practices, please revise the protection <br />of hydrological balance discussion in Section 2.05.6(3), the water depletion estimate in Section <br />2.04.11(4) and any other relevant permit section. <br />17. In the Probable Hydrologic Consequences Section 2.05.6(3)(b)(iii) on permit text pages 2.05- <br />49 and 2.05-50, it is stated that surface water is unlikely to recharge the alluvial ground water <br />system. Please add specific information to the discussion that supports this assertion. <br />18. Please provide the source of the predicted sediment pond discharge water quality data <br />presented in the Probable Hydrologic Consequences table on permit text page 2.05-52 of <br />Section 2.05.6(3)(b)(iii). <br />19. 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 the <br />discharge monitoring reports for the NPDES permit will be submitted to the Division on a <br />quarterly basis, as required in Rule 4.13(2)(a)(iii). <br />20. On page 2.05-57 of Section 2.05.6(3)(b)(iv), please add the species to be tested for each of the <br />chemical constituents presented in the hydrologic monitoring plan in Table 2. <br />21. Please explain why total species concentration was used in the surface water monitoring <br />program listed in Table 2 of Section 2.05.6(3)(b)(iv) on permit text page 2.05-57 since this <br />species has very limited use in the receiving stream standards of the CDPHE. <br />22. Please add hardness, flow, lab ph and lab conductivity to the list of surface water sampling <br />parameters in Table 2 on permit text page 2.05-57 of Section 2.05.6(3)(b)(iv). <br />23. Please add measurement units and minimum detection limits to each of the constituents listed <br />in Table 2 on permit text page 2.05-57 of Section 2.05.6(3)(b)(iv). <br />24. Referring to Map 08, "Hydrologic Monitoring Locations" for Rule 2.05.6(3)(b)(iv), please <br />explain why surface water monitoring stations US-LD and DS-LD are located as far upstream <br />3