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DRAFT ~ " = - - <br />12. OSM was concerned that the flumes were too large to sample <br />flow when spring and seep flow were being sampled. The lowest <br />reading on the flume's staff gauge equates to a flow of 4.48 <br />gpm. The trigger flow, as required in Trapper's PAP, for <br />initiating water quality monitoring of springs and seeps is <br />five gpm. OSM suggested that Trapper use a portable weir that <br />would provide more accurate readings at low flow. <br />13. OSM stated that it's position on water quality compliance is <br />that the point of compliance for all water quality standards <br />would be where the water flow leaves the disturbed area. The <br />Division stated that it's position is that NPDES standards <br />apply where the water flow leaves the disturbed area, but that <br />receiving stream standards apply after dilution with the <br />stream, in this case, the Yampa River. <br />1.4. OSM believed that "dozer basins" need to be permitted. <br />According to OSM, the permitting requirements would follow the <br />August 8, 1996 memorandum from Russell Price of the OSM <br />Western Support Center to the OSM Albuquerque field office. <br />15. OSM commented that one small gully across the light use road <br />leading to the Ute pond needs attention. <br />16. OSM believed that better access for equipment may need to be <br />provided in order to completely remove pond sediment.-~.~'i~ <br />The Division is in the process of reviewing all of these concerns. <br />The Division is working with Trapper so that these issues can be <br />resolved in a timely fashion. Please contact me if I left anything <br />off of this list or if I misstated OSM's position on an issue. <br />Sincerely, <br />Joseph J. Dudash <br />Environmental Protection Specialist <br />CC: Susan McCannon (DMG) <br />David Berry (DMG) <br />C:\WP51\TRAPPER\OSMTOPIC <br />