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~ - - <br />III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the <br />inspection and the facts or evidence supporting the enforcement action. <br />some of the lab reports stated that several samples were received <br />beyond the recommended holding times. Trapper acknowledged that, <br />due to sampling and shipping schedules, once in a while there is <br />difficulty in getting water samples to the laboratory, located in <br />Denver, on time. Trapper personnel also stated that the annual <br />water monitoring reports did not contain information on holding <br />time exceedances. The operator responded to this issue by agreeing <br />to work out a solution whereby holding times would not be exceeded. <br />Second, OSM personnel were of the opinion that Trapper's PAP should <br />contain a description of the surface water sampling procedures, <br />including the sampling methodology and the procedures for ensuring <br />holding times. The Division pointed out that Rule 2.03.3(4) already <br />requires that the operator follow a standardized methodology for <br />water quality sampling and lab analyses. However, the Division <br />agrees that having the protocol spelled out in the PAP can be of <br />value to Trapper's personnel. The Division recommends that the <br />water sampling procedures be listed in Trapper's PAP. <br />Third, it was suggested by OSM personnel that the cation-anion <br />balance be included in the lab analyses. The Division agrees. This <br />calculation would be simple to make and would point out whether or <br />not potential problems existed with the data. Trapper agreed to <br />look into the matter. <br />Fourth, OSM personnel were concerned that the surface water <br />sampling requirements for springs did not include a full suite <br />analysis, referred to by OSM as SMCRA water quality parameters. <br />What is currently required is the basic NPDES water sampling <br />parameters. The Division agreed to look into the matter. <br />NPDEB 8ITE8 <br />The Ute pond, NPDES outfall no. 008, was inspected first. The water <br />in the pond was within one foot of discharge. The flume, with the <br />staff gauge intact, was functional. There was no continuous <br />recorder on for now. The concrete single open channel spillway had <br />the design capacity and the outlet of the spillway was well <br />grassed. The sediment cleanout level marker was in place and showed <br />that cleanout was not necessary. The pond embankment appeared to be <br />stable. The seep that, earlier this year had saturated a small area <br />2 <br />