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<br /> <br />COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br />Rationale - Page 9. Permit No. CO-0026981 <br />CHANGES SINCE PUBLIC NOTICE: (Continued) <br />The compliance schedule includes the following steps: <br />1. Preliminary Assessment Report by December 15, 1987 <br />2. Submit Engineering Design and Costing Study by March 1, 1988 <br />3. Submit Final Engineering Report by May 15, 1988 <br />4. Achieve completion of project by December 1, 1988 <br />5. Achieve compliance with PART I, A.2. Effluent Limitations by January 1, <br />1989 <br />Additional specific project time schedules have been indicated in the June 2, <br />1987 letter from Camp Bird Venture. <br />With respect to the water quality-based effluent limitations of PART I, A.2., <br />it is recognized that these limitations have not been previouly applied to the <br />permittee, and with the previous operation and treatment processes that these <br />effluent limitations have sometimes not been achieved in the past. However, <br />previous treatment may not have been optimized to levels which might have met <br />these limitations. Also, alternatives for reduction of water flows into the <br />mine, reduction of mine discharge and/or identification of specific water <br />sources for treatment still need to be investigated. <br />In addition, although water quality-based effluent limtations have not <br />previously been in effect for this permit, the existing water quality standards <br />for Segment 9 were adopted January 10, 1983 and effective March 2, 1983 with <br />amendments for the Gunnison and Lower Dolores River Basins effective on January <br />30, 1984 and October 30, 1986. <br />As previously mentioned, Camp Bird Venture is presently involved in an ongoing <br />water quality and biological study of Canyon Creek, and will be presenting data <br />in a petition for a hearing to be scheduled before the Commission, planned for <br />the first quarter or half of 1988. Thus, this permit's water quality based <br />effluent limitations would be subject to modification if the Commission adopts <br />different numeric standards for Segment 9. Such change may affect this <br />permit's compliance schedule, if new standards are adopted. <br />Economic Reasonableness Evaluation <br />Section 25-8-503(8) of the revised (June 1985) Colorado Water Quality Control <br />Act required the Division to "determine whether or not any or all of the water <br />quality standard based effluent limitations are reasonably related to the <br />economic, environmental, public health, and energy impact to the public and <br />affected persons, and are in furtherance of the policies set forth in sections <br />25-8-102 and 25-8-104. <br />