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<br />OJ1702 <br /> <br />303(d) list and TMDLs developed, If the marginal cold water use was dropped from this <br />segment, then the water temperature standard of 32,20C would probably not be exceeded, <br /> <br />The standards for the different coldwater fishery uses, high quality cold water and marginal <br />coldwater, would be the most restrictive, Based on historical data, the State's latest 303(d) <br />listing and 305(b) report, and the low flow sample results, no acute fishery standards are <br />expected to be exceeded over long term 250 cfs releases from Navajo Reservoir. Of the chronic <br />fishery standards, it appears dissolved aluminum may be exceeded over the long term. One <br />sample site (above Highway 44 bridge at Bloomfield, NM) had a dissolved aluminum result two <br />times higher than the standard. The sample results from sites upstream and downstream had <br />results of about 1/3 of the standard. <br /> <br />The most likely standards to be exceeded over the long term between Navajo Dam and the <br />Animas River confluence are water temperature, conductivity, total ammonia, dissolved oxygen, <br />and total organic carbon. <br /> <br />In initial discussions with the State on the low flow test, the State feels the antidegradation policy <br />(section 20,6.4.8) in the Standards for Interstate and Intrastate Surface Waters would protect <br />present stream segment water quality from further degradation due to flow releases from Navajo <br />Reservoir. This section could provide the legal authority for the State to enforce the standards <br />through court proceedings. The NM Environment Department realizes that Reclamation is <br />attempting to return the San Juan River to a more natural hydrograph and generally supports that <br />effort, Further talks are needed with the state to clarify issues on the long term effects of 250 cfs <br />flows. <br /> <br />The NM Environment Department expressed concerns about effects on National Pollution <br />Discharge Elimination System (NPDES) permit holders if 250 cfs occurred during most of the <br />year. These permits would be primarily for wastewater treatment plants and power plants along <br />the river. The change in flows could affect the discharge limits on the permits which may require <br />the permit holders to make changes in their operations, upgrade equipment, etc. Reclamation <br />may conduct preliminary studies (from the dam to the confluence of the Animas River) to <br />determine if permitted constituents change significantly at the wastewater treatment plants. <br /> <br />In an earlier low flow test, the Four Comers power plant expressed concerns about managing <br />Morgan Lake during low flows due to increases in TDS in the San Juan River. These low flows <br />occurred during the four-month flow test (1996-97) in which flows between Farmington and <br />Shiprock were around 200 to 300 cfs. According to the flow recommendations developed by the <br />San Juan River Basin Recovery Implementation Program, 500 cfs would be maintained in the <br />San Juan River between Farmington and Lake Powell. This flow would be higher than the <br />critical low flows of the waste water treatment plants in Farmington and Shiprock and the two <br />power plants in this reach, so the NPDES permits would not be affected, <br /> <br />Long-term impacts to salinity should not be significant. Overall water volume delivered <br />downstream of New Mexico will not change, just the timing, The large spring runoff period will <br />have lower total dissolved solids, while the lower flows will have higher values, Results from <br />previous low flow tests and historical data show total dissolved solids increase during low flows. <br />Reclamation continues to look for ways to reduce salinity under the Colorado River Basin <br /> <br />Page 14 of 15 <br />