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~, <br />only one sample is required during the monthly measurement period." So if Colowyo <br />chooses to open and close a manual gate 5 times during a month, they only have to <br />collector report one sample to WQCD. The same comment applies for their weekly <br />definition, as well as quarterly. It should be made clear that each time gates aze opened <br />and subsequently closed that new samples are required for the next opening of any gate. <br />This will ensure compliance for all discharges. They state "These definitions clazify our <br />understanding that only one sample per measurement period is required for intermittent <br />discharge." This is not DMG's understanding from discussions with WQCD. This issue <br />needs to be clarified. <br />DMG Comments to Rationale and Permit <br />Page 8, V.B.1 Compliance with Terms and Conditions of Previous Permit. <br />It is stated in the second paragraph "it is not necessarily we for facilities such as this one that <br />have no other option under normal circumstances than to manually empty a pond." This <br />statement is inaccurate. Colowyo's pond's have primary and emergency spillways, Without <br />considering the manually operated gate. These two spillways aze the only spillways considered <br />in the pond design and are always open and available for discharge. Manual discharge from a <br />gate at the designed sediment level is optional at all times and has n to hing to do with r~ainine <br />caoacitX. This has been discussed numerous times with WQCD. Language on page 10 under <br />Alternate Limitation Burden of Proof Requirements should also be changed to reflect reality as <br />well. <br />Language should also be included to clearly indicate and differentiate between manual <br />intermittent discharges and automatic intermittent discharges. One quarterly sample from a gate <br />valve opened and closed 5 times during the quarter is meaningless. <br />