2021-12-07_PERMIT FILE - M2021058

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, r December 3, 2021 Page 2 The District cannot operate or provide sewer service for the City of Leadville and surrounding area without a constant flow of water to its treatment facility or if there is an interruption of sewage into the facility. The District is particularly concerned about the potential for breakage or severance of the line carrying sewage from the City to its treatment facility,which could result in the City's sewage flowing across US Highway 24 and ultimately into the Arkansas River. In order to preserve its rights,the District is filing this general objection to the Application. The District's Colorado Discharge Permit System ("CDPS") permit from the Colorado Department of Public Health and Environment ("CDPHE") requires the District to sample and analyze effluent for the following pollutants: arsenic,cadmium,chromium,copper,lead,mercury, molybdenum, nickel, selenium, silver, zinc, cyanide, and phenols. The District spends significant amounts of time and money trying to comply with its discharge permit and cannot afford to have its operations jeopardized by any nearby activities that might impact its ability to meet CDPHE's strict permit limits. The District is also operating under Cease and Desist Order No. DO-181109-1 dated November 9, 2018, issued by CDPHE and requiring the District to comply with permit effluent limitations, specifically for the 30-day average mercury limit of 0.077 µg/L. Low level mercury is present throughout Leadville in the soil, water, and air due to historic mining operations. The District is concerned that the Applicant's proposed operations will only make it more difficult to meet the CDPS permit limits and comply with CDPHE's Cease and Desist Order. For the reasons set forth above and others yet to be determined, the Leadville Sanitation District requests that the Application be denied. Very truly yours, Stephen A. Bain cc: Joseph Fattor