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~' <br />COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br />Rationale - Page 19. Permit No. CO-0024562. <br />(b) Monitoring Frequency: The permittee requested that the <br />monitoring frequency be decreased from weekly to twice monthly. This <br />change was requested for the following reasons: the effluent quality <br />has been consistant over the life of the permit and weekly monitoring <br />would be expensive both for the analysis itself and for the personnel <br />costs to travel to the discharge point. The Division will allow <br />decreased monitoring as long as there is no active mining or <br />exploration based on the consistant quality of the discharge. Once <br />any active mining or exploration occurs in the Carlton Tunnel, <br />monitoring frequency will increase to weekly. The permit and <br />rationale Have been changed to reflect these monitoring requirements. <br />The Division does recognize that the discharge point is not <br />conveniently accestable. A provision has been included in the permit <br />to exempt the permittee from collecting samples when weather <br />conditions make travel on the Gold Belt Scenic Byway impossible or <br />unsafe. <br />(c) Whole Effluent Toxicity Testing: The permittee has requested <br />that acute and chronic whole effluent toxicity testing be performed <br />with the Daphnia magna instead of the Ceriodaphnia sp. The Division <br />is only able to approve the use of other species if their sensitivity <br />to potential pollutants is equivalent to or more than that of <br />Ceriodaphnia sp. and if there are acceptable methods and procedures <br />for testing alternate species. This demonstration has not been made. <br />If the permittee would like to supply the necessary information to <br />make this demonstration, the Division will consider the approval. No <br />changes have been made to the permit at this time. <br />(d) Footnote 1/: The permittee requested that the parameter names in <br />the footnote be changed from total recoverable to potentially <br />dissolved to be consistant with the requirements of the permit. This <br />change has been made in the permit. <br />(e) Facility Contact: The facility contact has been changed to read <br />E.T. Hunter, Manager, Permits and Cultural Resources. <br />2. Comments made by EPA: <br />(1) WET Limits: EPA objected to the lack of enforceable WET limits. <br />WET limits have been added to the permit. <br />(2) Cadmium and Mercury Monitoring: EPA felt that cadmium and <br />mercury should be at least monitored when no mining activity is <br />occurring in the Carlton Tunnel. EPA noted that background cadmium <br />levels are above the chronic stream standard as shown in Table VI-2. <br />Upon review, it was discovered that Table VI-2 is incorrect. The <br />chronic stream standard for cadmium is 0.0021 mg/1 not 0.0002 mg/1 and <br />is greater than the ambient concentration of 0.00055 mg/1. The table <br />has been corrected. Past cadmium and mercury concentrations in the <br />discharge have been consistant and less than the stream standards. <br />Monitoring for both parameters will be included if any mining activity <br />occurrs in the Carlton Tunnel. Monitoring for these parameters will <br />not be added to the permit for discharges preceeding any mining <br />activity. <br />