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I I I I I I I I I I I I I I I I I I I 37(11 COLORADO WATER CONSERVATION BOARD J. William McDonald Direclor MEMORt\NDUM TO: Dan Law Dean SUndt PB FROM: DATE: November 17, 1981 SUBJECT: Colorado Water Quality Control Commission policy for Implementing the Colorado River Salinity Standards through the NPDES Permit Program The Regulations concerning this subject were adopted on March 7, 1978 and became effective on May 10, 1978. For all new industr ial discharge I permits issued after May 10, 1978, and all existing industrial discharge permits up for reissuance after May 10, 1978, the Water Quality Control Commission has required that salinity be sampled on a monthly basis until six samples have been analyzed. Following submittal of the first six months of data, the Commission shall determine the eligibility for a waiver of the no salt return policy based on salt-loading of less than one ton per day. If this waiver cannot be granted, the permittee has an additional six months to submit a report addressing the economic practicability of achieving salt removal in accordance with Regulations 3.10.0-3.10.5 and Appendix A. Continued monitoring for salinity is required.regardless of whether the less than one ton/day waiver is granted or the practicability of salt removal study proves uneconomical. The pOlicy with regard to municipal discharge permits is much the same with one exception. The Commission shall allow municipal discharges to release water with an incremental increase in salinity of 400 mg/L or less above the flow weighted average salInity of the intake water supply. Discharge in excess of the 400 mg/L incremental increase may be permitted upon satisfactory demonstration by the permittee that it is not practicable to attain the limit. At this time, there are very few permits for which the implementa- tion of no salt return policy has not been initiated. These instances involve older permits up for reissuance and are currently being re- written to require salinity monitoring. Although the implementation of the policy has been initiated in most cases, completion of the process has been slow. This is primarily due to the fact that many of the industrial discharges to the Colorado River Basin in Colorado are coal mine sedimentation ponds. The ponds are often>times designed for full containment making it difficult to obtain the first six months discharge data. In all situations where the first six months data was available in the minimal amount of time and salt-loading exceeded one ton/day, the permittee has been able to convincingly demonstrate that salt removal is not economically practicable DS:cs -34-