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Requirement <br />Regulation <br />Reviewed <br />Comment <br />H. Antidegradation <br />MCC <br />regulations <br />Trapper is not subject to the Antidegradation Rule because <br />Rule for Surface <br />3.1. 9(2) and <br />NA <br />the receiving waters (Segment 3b of Lower Yampa River) <br />"Use- <br />Water <br />J.J.O. <br />are designated Protected." <br />I. Interim Narrative <br />CWQCC <br />Standard for <br />regulation <br />Yes <br />Ground Water <br />41.5.C.6 <br />Sampling frequency changed during the fourth quarter due to <br />Table 4.8 -11 <br />NPDES permit renewal and TR110. Overall, it appears <br />J. Sampling <br />ofCDRMS <br />Trapper has conducted surface water monitoring in <br />frequency at <br />mining <br />Comment <br />accordance with the approved monitoring frequency. Several <br />surface water <br />permit C -81- <br />issues in regards to the parameters monitored were noted <br />monitoring sites <br />010 <br />upon review of the surface water monitoring data submitted. <br />These items are discussed in detail in the next section. <br />• Zinc is a parameter to be monitored semi - annually- <br />for outfalls required to report list A -3 parameters. <br />zinc measurements were not reported in the AHR. <br />Trapper will need to monitor and report Zinc levels <br />as required by the monitoring plan. <br />• For outfall 002, 005, 011, 013, 014, 015, 017, 018, <br />020 and 021 no settleable solids measures were <br />reported in the AHR for 2012. Settleable solids <br />values were reported in the first, second and third <br />quarter discharge monitoring reports. For the fourth <br />quarter, settleable solids are required to be reported <br />as an alternate limitation in the event of an <br />exceedance of the primary effluent limitation during <br />a precipitation event. It appears the majority of the <br />settleable solids values recorded throughout the year <br />K. Parameters to be <br />Table 4.8 -12 <br />were simply not transferred to the AHR for 2012. <br />sampled at <br />of CDRMS <br />• Total suspended solids was not reported on a <br />surface water <br />mining <br />per mit C -81- <br />per <br />Comment <br />monthly basis for Outfalls 001, 011 and 020 for this <br />sites <br />year. <br />• For outfalls 001, 002, 011, 014, 017, 018, 020 and <br />021; iron was not reported monthly as required. Iron <br />was monitored and reported in the required NPDES <br />discharge monitoring reports. However, these values <br />need to be reported in the AHR. <br />• Total dissolved solids was not monitored during the <br />fourth quarter of 2012 for outfalls 011 as was <br />required. <br />• Aluminum was not reported semi - annual as required <br />by the monitoring plan for outfalls 011. <br />• No discussion of observations of oil and grease are <br />included in the AHR. Oil and grease are monitored <br />in the discharge monitoring reports submitted to <br />CDPHE and copied to the Division. <br />Page 2 <br />