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treatment or that may otherwise be in the dischazge. Colowyo listed two flocculants/settling agents which were approved for use by the WQCD and may be added directly to the water in Colowyo' s sediment control ponds. Colowyo also stated that the "Diversey Lever, Reilly Wendover, and Hadco Chemical products only have the potential to be introduced into a sediment pond, the product will not be directly applied to a pond." These three products are used for the cleaning of vehicles, haulroad dust suppression, and the de-icing of walkways and railcars. The language in the new draft WQCD Rationale document, dated August 11, 1997 is incorrect. It is not necessary to "pump" the water from the Washbay Pond to the Work Area Pond (Outfal1002b) because the water can be transferred via gravity flow and therefore does not require pumping. 6. Please refer to the GENERAL COMMENTS section of the letter for a discussion of the present and future operation of Colowyo's sediment control ponds. The CDMG has copies of all of Colowyo's hydrological modeling and the CDMG is encouraged to review each modeling effort. Colowyo would be pleased to review pond hydrology/sedimentology models with the CDMG. Again, Colowyo' s ponds aze not currently designed as automatic dewatering ponds. Please refer to the GENERAL COMMENTS section of the letter for a discussion of the present and future operation of Colowyo's sediment control ponds. The CDMG has copies of all of Colowyo's hydrological modeling and the CDMG is encouraged to review each modeling effort. Colowyo would be pleased to review pond hydrology/sedimentology models with the CDMG. 8. Colowyo 'did submit letters to the WQCD providing an explanation for all exceedances of the Primary Effluent Limitations and requests for using the Alternate Limitations, as well as more lenghtly letters setting forth Colowyo's position that the exceedances were not permit violations. WQCD never responded to these letters. As further evidence of the seriousness with which Colowyo treated the exceedances, Colowyo also met extensively with the WQCD and the CDMG to review these issues' One issue throughout these discussions was Colowyo's entitlement to the Altemate Limitations for manual headgate dischazges which Colowyo relied on. In an October 3, 1994 letter from WQCD to Colowyo, WQCD granted Colowyo the authority to use the Altemate Limitations for manual headgate dischazges when such dischazges were necessary to maintain pond capacity for additional inflow. After the letters and meetings, the WQCD issued a letter on May 14, 1996, agreeing with its 9Meetings held on February 28, 1996; March 27, 1996; and Apri126, 1996. tz