2011-07-11_APPLICATION CORRESPONDENCE - C2010088

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Mike Boulay -7- July 8, 2011 Division Response: The well designations relative to the corresponding As- Built Drawings from 1981 when the wells were drilled and completed is not described in the permit text. The discussion for RW -2 on page 4 of the AVF report with regard to its location and corresponding well log is also unclear. Please add the following description to page 2.04 -14 (after the 4th paragraph) to clarify the well designations and their corresponding completion log. This discussion is paraphrased from the AVF report. "The number designations for the monitoring wells now being utilized have changed somewhat since they were originally installed. The As -Built Drawings provided in Exhibit 14, Appendix B for RW -la, RW -3, and RW -4 are the active monitoring wells RW -1, RW -3, and RW -4, respectively. The well log and location for RW -2 given in Exhibit 14, appendix B is not the same well as is currently being monitored. As previously described the current monitoring well RW -2 was installed at a later date and is located northeast of the acid sludge landfill. There is no well completion log or other as -built drawings available for this well. The total depth and stickup were field verified and the best available information was added to the typical completion diagram provided in Exhibit 3. The typical completion diagram in Exhibit 3 provides the most current and best available information for the four active monitoring wells RW -1 through RW -4." CAM - The suggested paragraph was added to pages 2.04 -14, 15 & 16. 11. Division Response: Response accepted. 12. Division Response: Response accepted. 13. Rule 2.04.7(2)(a) requires that the baseline surface water data show seasonal variations in the quantity and quality of the surface water. However, only two quarters of the baseline surface water data are presented in Exhibit 3 of Volume II. Please submit additional baseline surface water data in compliance with Rule 2.04.7(2)(a). CAM #1 Response: Please see revised Exhibit 3 providing third and fourth quarter monitoring data. Division Response: The Division has no further concerns at this time. In the submittal dated April 11, 2011, CAM updated the water monitoring data in Appendix 3 to include monitoring results for all four quarters of 2010. Since the Lower Downstream Loma Drain surface water station was recently added, only one quarter of data has been provided. Additional baseline sampling results will need to be submitted for this station. CAM - Monitoring continues on at the Lower Downstream Loam Drain monitoring station. Two quarters are available and a third quarter will be collected in June.