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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 Page 50 <br />sediment pond discharges to the leachate from the coal pile and calculate a weighted <br />average for the combined leachate. <br />CAM Response: The Operator does not believe leachate will enter the groundwater. <br />Please see discussion on page 2.05.51. <br />Division Response: There is no discussion of the potential for discharge to shallow alluvial <br />groundwater from the sediment pond bottoms on page 2.05 -51 as stated in CAM's <br />response. The Division understands that the sediment ponds have been redesigned and the <br />likelihood of this occurring is lessened as a result. Please add an appropriate discussion <br />regarding the potential for leachate from the sediment ponds discharging to shallow <br />groundwater. <br />90. On page 2.05 -51 potential impacts to groundwater are described. For ease of comparison <br />please add a table that shows leachate data compared to groundwater data from well RW -1. <br />CAM Response: A column for RW -1 has been added to the existing table and page 2.05- <br />51, and the existing table on page 2.05 -52. <br />Division Response: Response accepted. <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 />CAM Response: There is a discussion on points of compliance under 2.05.6(3)(b)(iv), <br />page 2.05 -54, first paragraph, that states, "The applicant asserts the coal operation does not <br />have the potential to negatively impact the quality of groundwater for which quality <br />standard have been established by the Water Quality Control Commission ". However, <br />RW -3 is available as a point of compliance, as stated in section 2.05.6(3)(b)(iv). <br />Division Response: Response accepted. Please note that the Division may at a future <br />time require that one or more points of compliance be established for the Fruita <br />Loadout. Please correct the typo in the Iast sentence of the first paragraph on page <br />2.05 -58 (standard should be plural). <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? <br />