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Welborn Sullivan Meck&Tooley&Leadville Sanitation 2
<br /> June 9,2023
<br /> and cannot afford to have its operations jeopardized by any nearby activities that might
<br /> impact its ability to meet CDPHE's strict permit limits.
<br /> The District is also operating under Cease and Desist Order No. DO-181109-1 dated November
<br /> 9, 2018, issued by CDPHE and requiring the District to comply with permit effluent limitations,
<br /> specifically for the 30-day average mercury limit of 0.077 ug/L. Low level mercury is present
<br /> throughout Leadville in the soil, water, and air due to historic mining operations. The District is
<br /> concerned that the Applicant's proposed increased operations will only make it more difficult to
<br /> meet the CDPS permit limits and comply with CDPHE's Cease and Desist Order. See JVA
<br /> Memo.
<br /> JVA Reference:
<br /> The District is currently under a compliance schedule to reduce inflow and infiltration into the
<br /> collection system. Inflow is water, other than wastewater, that enters a sewer system from
<br /> sources such as roof leaders, cellar drains, yard drains, area drains, foundation drains, drains
<br /> from springs and swampy areas, manhole covers, cross sections between storm drains and
<br /> sanitary sewers, catch basins, cooling towers, storm waters, surface runoff, street wash waters
<br /> or other drainage. Inflow does not include, and is distinguished from, infiltration. (2) Infiltration
<br /> is water other than wastewater that enters a sewer system (including sewer service
<br /> connections and foundation drains) from the ground through such means as defective
<br /> pipes, pipe joints, connections, or manholes. Infiltration does not include, and is
<br /> distinguished from, inflow.
<br /> (2) The new crushing facility could impact the collection system by disturbing the
<br /> manholes, pipes and service lines resulting in an increase in the infiltration of
<br /> groundwater into the collection system. This increase in infiltration is in direct conflict
<br /> with the CDPHE compliance schedule to reduce inflow and infiltration into the collection
<br /> system. Damage to the collection system could also result in exflltration or seepage of
<br /> wastewater into the ground which would be a direction violation of the Clean Water Act.
<br /> The District's WWTF consists of a headworks for screening and grit removal, two aeration
<br /> basins, two covered clarifiers, a polishing pond, and a chlorine contact chamber for disinfection.
<br /> The District is also under the Colorado Department of Public Health and Environment
<br /> (CDPHE/Division), Water Quality Control Division Notice of Violation /Cease and Desist Order,
<br /> Number: DO-181109-1 (NOV/CDO) dated November 9, 2018. The NOV/CDO sited a failure to
<br /> comply with permit effluent limitations, specifically for the 30-day average mercury limit of 0.077
<br /> ug/L. The District is required to follow a compliance schedule to identify sources of mercury to
<br /> the WWTF and implement strategies to control sources so that compliance with the total
<br /> mercury effluent limitation could be attained.
<br /> Low level mercury is present throughout Leadville in the soil, water and air due to historic mining
<br /> operations. The potential for increased infiltration into the sewer collection system as previously
<br /> stated from the new crushing facility could increase mercury and other metal constituents to the
<br /> WWTF possibly resulting in effluent compliance issues for the District.
<br /> The WWTF operates under the Colorado Discharge Permit System Permit Number
<br /> CO0021164. The District's permit establishes effluent limits for potentially dissolved copper and
<br /> cadmium ranging from 1.1 to 1.6 ug/L depending on time of year. The permit limit for total
<br /> mercury is 0.077 ug/L. The permit also establishes limits for potentially dissolved zinc ranging
<br /> from 2658 to 480 ug/L depending on time of year.
<br /> (1) The permit also requires the District to report effluent limits for an extensive list of
<br /> pollutants including arsenic, chromium, copper, cyanide, iron, lead, manganese,
<br /> molybdenum, nickel, selenium, silver, uranium, sulfide, nonylphenol, cesium, radium,
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