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- . ~, <br />3. Ambient stream water quality should provide the basis for the <br />standards in Segment 13. In that Segment, the classified uses <br />presently exist despite the fact that ambient conditions reflect lower <br />water quality than the standards or the "tables" appended to the basic <br />regulations. Further, metals present in the water samples may be tied <br />up in turbidity when water is present in the stream. In this form, <br />they are not "available" to fish and may not be detrimental to aquatic <br />life. See CDOH, Water Quality Standards and Stream Classification, 5 <br />CCR 1002-8, Section 3.3.7(5)(f) and (g). <br />4. CYCC requests an immediate review of the existing standards, in <br />accordance with law, for the following reasons: <br />a. There exists a clear and present potential for inequity or <br />unreasonable economic impact because ambient water quality <br />exceeds the current standards. CYCC is likely to continue to <br />exceed the effluent limits established by its Permit, with the <br />resulting economic and administrative effect; <br />b. The existing standards materially affect CYCC's present decision <br />making, regarding treatment alternatives and requirements; <br />c. There exist evident errors in the standards which the Commission <br />should rectify before its three-year periodic review; and <br />Segment 13 may require more attention than it likely would <br />receive during the triennial review of the entire basin. <br />WHEREFORE, CYCC requests that the Commission amend the appropriate metal <br />standards far Segment 13 of the Yampa,River to reflect ambient water quality. <br />Dated ~,....-- ZG* ~ 9 fry <br />COLORADO YAMPA COAL COMPANY <br />~ _ ;1 <br />C. Gene Consalus <br />Uice President and General Manager <br />CGC/fc <br />