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2011-07-11_APPLICATION CORRESPONDENCE - C2010088
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2011-07-11_APPLICATION CORRESPONDENCE - C2010088
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Last modified
8/24/2016 4:35:29 PM
Creation date
7/11/2011 10:38:45 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C2010088
IBM Index Class Name
APPLICATION CORRESPONDENCE
Doc Date
7/11/2011
Doc Name
Adequacy Response #1
From
J.E. Stover & Associates, Inc
To
DRMS
Email Name
MPB
SB1
Media Type
D
Archive
No
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Mike Boulay <br />-35- July 8, 2011 <br />establishing a groundwater point (or points) of compliance at the Fruita Loadout, <br />and specify which well or wells will be available as point of compliance well(s) for <br />the alluvial groundwater. The PAP should address the need for points of <br />compliance and be updated accordingly. <br />CAM Response: There is a discussion on points of compliance under <br />2.05.6(3)(b)(iv), page 2.05 -54, first paragraph, that states, "The applicant asserts <br />the coal operation does not have the potential to negatively impact the quality of <br />groundwater for which quality standard have been established by the Water <br />Quality Control Commission ". However, RW -3 is available as a point of <br />compliance, as stated in section 2.05.6(3)(b)(iv). <br />Division Response: Response accepted. Please note that the Division may at a <br />future time require that one or more points of compliance be established for <br />the Fruita Loadout. Please correct the typo in the last sentence of the first <br />paragraph on page 2.05 -58 (standard should be plural). <br />CAM - Comment noted. The typo was corrected on page 2.05 -62. <br />92. Division Response: Response accepted. <br />93. There is no discussion of the Colorado River in the PHC. CAM is proposing to <br />divert water from Loma Drain and Reed Wash and there are proposed discharges <br />to Reed Wash. Since the site is in close proximity to the Colorado River and both <br />Loma Drain and Reed Wash ultimately drain to the river there should be some <br />conclusion and quantification of impacts (if any) added to the PHC discussion for <br />the Colorado River. <br />CAM Response: There is a discussion of the Colorado river under section <br />2.05.6(3)(b)(iv), page 2.05 -55, the Operator states, "The Colorado River will not be <br />monitored because of its high flow rate. Any potential impacts to the Colorado <br />River could not be detected because of the high dilution factor". <br />Division Response: CAM's reference to page 2.05 -55 is incorrect. The statement <br />regarding the Colorado River is on page 2.05 -59. The discussion for the Colorado <br />River needs to be further clarified (see Division's previous comment 15A regarding <br />sampling of the Colorado). We believe that it was CAM's intent to collect <br />baseline data for the Colorado River but not include it in the quarterly <br />monitoring program. If this is the case, then this should be stated on page <br />2.05 -59. Please also add a statement that the Colorado River upstream and <br />downstream monitoring locations will be resampled on a quarterly basis for <br />one -year prior to bond release to verify the conclusions of the PHC that there <br />are no detectable impacts to the Colorado River. Please expand upon the <br />discussion of the Colorado River accordingly. <br />
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