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i'>-:1r~ <br />I ~ required BOD limitations. The following summarize relevant considerations with respect to this <br />consideration: <br />1) TCC has consistently met the applicable limitations on effluent BOD levels. Please refer to <br />previously submitted DMR's (copies can be provided on request). <br />2) Although currently meeting the applicable effluent BOD level limitations on a consistent basis, <br />TCC must treat the influent down to a significantly lower BOD concentration in order to meet <br />the current percent removal requirements. As an example, based on the recent BOD percent <br />removal exceedance where we treated down to 27 mg/1 (from a starting effluent of 74 mg/1), we <br />would have to treat down to 11 mg/1 to meet the 85-percent removal requirement. The <br />associated incremental treatment requirements and costs of reducing effluent BOD below <br />applicable BOD level limitations represent an undue and unnecessary burden. <br />3) As previously indicated, the influent water includes significant grey-water dilution, however <br />despite this fact, TCC has not exceeded our permit effluent flow limitation of 0.015 MGD (30 <br />day average) at the effluent outfall. <br />TCC is incrementally increasing production, with the associated need to hire additional employees. In <br />order to address the expanded workforce, TCC is in the process of expanding the existing bathhouse <br />facilities. This will result in increased influent flow volume to the system, as well as increased grey- <br />water dilution. As indicated in our phone conversation, we have contracted with Mr. Dick Bowman, <br />former head of the Grand Junction CDPHE-WQCD Office, to review our existing wastewater handling <br />and treatment system and provide recommendations on any necessary upgrades or modifications. <br />Based on his preliminary review and recommendations, we anticipate eliminating roof-drain <br />contributions to the system, increasing system aeration, and making other minor system modifications <br />this spring and summer <br />We appreciate your consideration and the assistance and advice that you and Mr. Andrew Newhart <br />have provided regarding this issue. Please feel free (yourself or other appropriate person) to contact <br />me at (970) 870-2750 with any questions regarding this request or related matters. <br />Best regards, <br />Twentymile Coal Company <br />Brian A. Watterson, P.G. <br />Geologist, Environmental Group <br />Enclosures <br />cc: DMG - CWPS Permit No. CO-0042161 file <br />J. Nettleton/TCC <br />