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are specifically set to account for storm event size, Colowyo indicates that "It is possible <br />that these exceedances would have been the same, or perhaps even higher, had the ponds <br />been operated in the treatment mode ..." but they offer no proof. The assertion than <br />aquatic vegetation is to blame for high levels of regulated pollutants is absurd. The <br />amount of sediment on aquatic vegetation is insignificant in comparison to runoff <br />entering the pond. The ponds are not designed to be manual discharged during or <br />shortly after storm inflow. This has been discussed numerous times with WQCD. <br />Colowyo also inaccurately misstates that "Colowyo simply had no choice but to <br />discharge from the ponds ..." This is simply not true, as most of the ponds aze designed <br />to discharge through the principle spillway, during the storm event and shortly after. The <br />problem is Colowyo chooses not to allow this dischazge, but instead, chooses to discharge <br />from a much lower stage in the pond (the manually operated gate) where the water is <br />much worse in terms of sediment concentration. <br />Finally, the language with regazd to the primary limitations should stand, as is. <br />Colowyo's misunderstanding of permit requirements is a Colowyo internal issue and <br />should not be part of any rationale. <br />9. Again, Colowyo is attempting to open the door so that manual discharges can be made <br />within the alternate limitations. No pond, with the possible exception of the washbay <br />pond, has only manual dewatering capability! The original language is appropriate and <br />necessary. Colowyo is attempting to get approval to leave the lower dewatering gate on <br />their ponds open, for extended periods, and argue that they must do this to maintain the <br />capacity to hold the 10 year 24 hour storm. This means that during the 3-month + period <br />of snow melt, the pond will effectively be removed from the ~, sv tem. How do they <br />propose to sample and report `pit pumped water' and separate it from storm runoff or <br />snowmelt? <br />10. No comment. <br />11. No comment. <br />Comments on Colowyo Letter to WOCD - CPDS Permit Document <br />Original language should stand. Again, the Colowyo is attempting to find a way to <br />discharge without treatment. The additional language is a cleaz attempt to confuse the <br />containment/treatmentlssue. <br />2. No comment. This is entirely a WQCD issue. <br />No comment. <br />4. In Colowyo's proposed definition of monthly they state "If the discharge is intermittent, <br />