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TR-15 Concerns <br /> Page 2 <br /> Item 3 . - Cont 'd <br /> 3 . From this information, a definite service life cannot be <br /> ascertained but the proposed usage is a normal construction <br /> use for the product, polypropylene is considered inert in <br /> soils and testing has shown no product breakdown after 15 <br /> years. <br /> SGC requests that the gradation criteria stated in Item 3 . not <br /> be a requirement for construction although SGC is not opposed <br /> to doing sieve analysis and trying to match onsite materials <br /> and those that have to be purchased in an effort to provide <br /> additional protection to the system over and above that <br /> provided by an inert geotextile (Supac or equivalent) . <br /> Not knowing the gradation of the materials to be encountered, <br /> it is hard to evaluate the economic impact this requirement <br /> could entail . Under worst circumstances, it could involve <br /> importing (probably from Durango) enough material to make the <br /> project cost prohibitive. Since a failure of the system <br /> proposed would not cause safety concerns or be significantly <br /> different than if the system is not installed, SGC proposes <br /> this requirement be made a recommendation. If the Division <br /> has reasons (ie. case studies) to suspect the effectiveness of <br /> geotextiles, I would appreciate any information that could be <br /> made available to me so we could re-evaluate our confidence in <br /> the products. <br /> In reviewing the TR-15 submittal, the proposed geotextile <br /> installation could be improved by completely wrapping the <br /> aggregate with an overlap on top. SGC proposes that this <br /> change become part of the TR-15 submittal . <br /> 4 . SGC will provide ditch sideslope stabilization, either <br /> vegetation or rip-rap, for the proposed ditch. As builts will <br /> be provided regarding the requested details. <br /> 5. The Colorado Department of Health (CDH) was contacted and an <br /> answer was received concerning any required NPDES permits for <br /> this project (Copied to DMG) . It is still unclear whether the <br /> CDH will require a Stormwater permit (which has been applied <br /> for) or a water quality based point discharge permit. This <br /> can only be determined by a possible site inspection by the <br /> CDH and/or agreement between CDH and DMG on site conditions . <br /> If a water quality based point discharge permit is required , <br /> SGC believes the project is unfeasible as there is no reliable <br /> mechanism for discharge of obligations. <br /> 6 . The State Engineer has determined a well permit application is <br /> required (see enclosed letter) . A well permit application <br /> will be submitted upon receipt of TR-15 approval by the DMG <br /> and a decision being received on Item 5 above . <br />