Commentaire
Part 1: I am writing to object to the renewal of the PTTW for CRH Canada Group Inc. at the locati is stated as non-transferable and this remains as condition 1.4 in the current permit. If the original permit is non-transferable, how, why and under what circumstances was it transferred from the original owner to CRH Canada Group Inc. on August 14, 2017? I believe this permit should not have been transferred in August 2017 and as such, a new application is required and any continued use of well PW1-09 should NOT be permitted. 2. It would appear the consulting firm GHD has prepared the application for renewal. Under section 2 of the application, they state that "as a general rule of thumb, they expect 10% loss to groundwater flow under non-pumping conditions". This statement is non-scientific and is not supported by any site specific-evidence. I would expect a company to offer specific evidence-based findings in support of this application and as such, subjective non-supported comments like "rule of thumb" should be rejected and more study on specific losses to groundwater should be required. In recent community liaison meetings, CRH corporate officials have acknowledged an 85% loss in water pumped vs. water retained and have described their pond system as "closed loop system with leaking ponds". Given the water pumped is used to wash gravel, and is now laden with very fine glacial sediments that tend to stay in suspension, management of this wash water is a critical issue. Section 3.2.1 of their report indicates draining is primarily via infiltration into the groundwater flow in a northerly direction. This upper aquifer is the source water for the contaminated wells locally and remains a critical concern for adverse effect from washing operations.
[Original Comment ID: 213764]Soumis le 17 mai 2019 11:31 AM
Commentaire sur
CRH Canada Group Incorporated - Permit to take water
Numéro du REO
013-2282
Identifiant (ID) du commentaire
30053
Commentaire fait au nom
Statut du commentaire