2011-06-21_APPLICATION CORRESPONDENCE - C2010088

• Permit No: C2010088
• IBM Index Class Name: Application Correspondence
• Doc Date: 6/21/2011
• Doc Name: Adequacy Review No. 2
• From: DRMS
• To: CAM Colordo, LLC
• Email Name: MPB
• Email Name: SB1
• Media Type: D
• Archive: No

Corey Heaps
CAM Colorado LLC
June 21, 2011 Page 51
CAM Response: Each pond will be dewatered by pumping. A value of 100 gallons per
minute is an assumed value that is reasonable for a 2" gas powered pump. It is unknown at
this time the exact pump that will be used, but 100 gallons per minute is a good assumption
for comparison purposes. Text has been added to page 2.05 -54 noting the use the
assumption.
Division Response: Response accepted.
93. There is no discussion of the Colorado River in the PHC. CAM is proposing to divert
water from Loma Drain and Reed Wash and there are proposed discharges to Reed Wash.
Since the site is in close proximity to the Colorado River and both Loma Drain and Reed
Wash ultimately drain to the river there should be some conclusion and quantification of
impacts (if any) added to the PHC discussion for the Colorado River.
CAM Response: There is a discussion of the Colorado river under section 2.05.6(3)(b)(iv),
page 2.05 -55, the Operator states, "The Colorado River will not be monitored because of its
high flow rate. Any potential impacts to the Colorado River could not be detected because
of the high dilution factor ".
Division Response: CAM's reference to page 2.05 -55 is incorrect. The statement
regarding the Colorado River is on page 2.05 -59. The discussion for the Colorado River
needs to be further clarified (see Division's previous comment 15A regarding sampling of
the Colorado). We believe that it was CAM's intent to collect baseline data for the
Colorado River but not include it in the quarterly monitoring program. If this is the
case, then this should be stated on page 2.05 -59. Please also add a statement that the
Colorado River upstream and downstream monitoring locations will be resampled on
a quarterly basis for one -year prior to bond release to verify the conclusions of the
PHC that there are no detectable impacts to the Colorado River. Please expand upon
the discussion of the Colorado River accordingly.
94. In the Probable Hydrologic Consequences Section 2.05.6(3)(b)(iii) on permit text pages
2.05 -49 and 2.05 -50, it is stated that surface water is unlikely to recharge the alluvial
ground water system and some general assumptions are provided. Please add specific
information to the discussion that supports this assertion.
CAM Response: Please see revised pages 2.05 -50 & 51.
Division Response: Response accepted.
95. In Section 2.05.6(3)(b)(iv) on permit text page 2.05 -58, it is stated that water monitoring
records will be maintained on site and submitted to the Division annually. Please add that
the discharge monitoring reports for the NPDES permit will be submitted to the Division
on a quarterly basis, as required in Rule 4.13(2)(a)(iii).