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<br />DIVISION OF MINERALS AND GEOLOGY <br />Dcpdrlnuml ul N,LUral Kesuur[e< <br />I i 1 i Sharman SL, Kuum ?15 <br />Dcnvar, ColnmAo µO203 <br />Phuna: i ill}l µh6-35fi7 <br />FAX'. (31141 H}?.µI06 <br />Memo <br />To: Dan Hernandez r <br />From: Kent Gorha ~p1ly <br />CC: Byron Walker <br />ltE: Colowyo Proposed CDPS Permit <br />I~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Rumcr <br />Guvernrn <br />lames 5. Luchhead <br />Ecewove Dueaor <br />hLC hael tl. Long <br />Urvrsmn DmeUnr <br />Below are my comments to Colowyo's comments, the rationale, and the proposed CDPS permit <br />for the Colowyo operation. <br />Comments on Colowyo Letter to WQCD on Rationale Document <br />Colowyo continues to maintain that their ponds are operated under a containment <br />scenazio. DMG inspections, however, document otherwise. snowmelt from the disturbed <br />area is allowed to exit the pond immediately, without containment or significant resident <br />holding time. Furthermore, pond designs do not reflect containment, but in fact, depict <br />significant discharge from the 10 yeaz 24 hour storm event, which is a treatment scenario. <br />2. No comment. <br />4. Original WQCD wording should stand. WQCD is the sole party who should determine <br />what constitutes "process water". This is clearly an attempt to weaken the identification <br />of waters that will be subsequently discharged. <br />5. Colowyo did not accurately state the sentence. The original sentence should stand. <br />6. Original WQCD wording should stand. Colowyo changes are incorrect. However, if <br />their language is adopted, the "prescribed period" of retention of snowmelt should be <br />specified. This would alter the current Colowyo practice of allowing snowmelt to exit the <br />dewatering gate with little or no detention time. <br />iii iiiiiiiiiiiiiiii <br />STATE OF COLU~~UU <br />Colowyo's problems are, in fact, due to manual dewatering. Snowfall, rainfall, and warm <br />weather have nothing to do with the problems. Burden of proof and alternate limitations <br />