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<br /> <br />COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br />Rationale - Page 7. Permit No. CO-0026981 <br />DISCUSSION: <br />1. Compliance With Permit Limitations - Appendix A contains a summary of <br />effluent data collected by Federal Resources and also by the Water Quality <br />Control Division. Exceedances of the previous permit's daily maximum <br />effluent limitations have occurred for TSS, lead and zinc. This data also <br />exceeds the 30-day average and daily maximum water quality-based <br />limitations for this permit which will be in effect by January 1, 1989 for <br />cadmium, copper, lead and zinc. Also, some mercury concentrations have <br />exceeded the daily maximum water quality based limit. Thus, to achieve <br />the water quality-based limitations, additional treatment will be <br />necessary. The compliance schedule on page lc of the permit necessitates <br />that treatment be utilized so that the water quality-based limitations <br />will be achieved. Presently, Camp Bird Venture is planning to do stream <br />studies for evaluation of stream low flow, ambient water quality data, and <br />biological data. The permittee must be aware that immediate metal limits <br />are for the total metal while limitations after January 1, 1989 are for <br />the total recoverable fractions. <br />2. Monitoring Frequencies <br />Three times per month monitoring is required for metal parameters and <br />TSS. Due to the large discharge flows from this major industrial <br />facility, previous noncompliance and the present inability to meet the <br />limitations of Table IV, monitoring is necessary for these parameters on a <br />3 X monthly basis. Total cyanide is required to be monitored on a monthly <br />basis. Flow, pH and Oil and Grease shall be monitored weekly to ensure <br />proper operation. Quarterly monitoring shall continue for TDS. <br />3. One Time Monitoring Analysis - Pages le and if of the permit contains a <br />six-time analysis for total recoverable iron and a one-time analysis of <br />some parameters for Discharge Point 001. Analysis of these parameters is <br />necessary to evaluate the impact of the discharge on the existing water <br />quality standards for Canyon Creek. The acid fraction of organic toxic <br />pollutants is required to be tested for facilities in this ore mining <br />category. <br />4. Signatory Requirements - Please refer to the signatory requirements on <br />page 4 of the permit which are due within 60 days of the effective date of <br />the permit. <br />5. Materials Containment Plan - Pages 6 and 7 of the permit describes the <br />Materials Containment Plan (AiCP) which is a requirement of all industrial <br />permits. Storage of gasoline, diesel and chemicals at the site will need <br />to be addressed in the MCP. <br />