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primary limitations when manually dewatering its ponds. We believe the originally <br />proposed language should remain. <br />in this same section, Colowyo wishes to revise language describing the exemption from <br />primary limitations for discharges from Outfalls 0026, 0046, 0076, 0086, 0096, and <br />OIOb when those discharges contain pit pumpage or vehicle washwater. Colowyo would <br />like to change the exemption to read "...unless the permittee can demonstrate that <br />surface runoff caused the exceedance of primary limitations." While we don't have a <br />problem with this particular proposal, we would have a problem with it if WQCD allows <br />exemptions from primary limits for manually operated discharges. If Colowyo were to <br />be allowed to manually discharge ponds without those discharges having to meet <br />primary limitations (because "surface runoff caused the exceedance"), then requiring pit <br />pumpage/vehicle washwater inflows to meet primary limitation would be of little <br />importance. We believe the language proposed by WQCD should remain. <br />Continuing on Page 6, under the same "Part I, A.2., Burden of Proof Requirements, <br />Permit Page 5;' Colowyo proposes that the last paragraph of this pact of WQCD's <br />permit be revised to read "All of Colowyo's ponds are currently operated as containment <br />ponds". While this may be true, they are not designed to be so operated. The ponds are <br />designed to be operated as treatment ponds. <br />Colowyo goes onto say that "Such ponds shall be considered to have only manual <br />dewatering capability." This is currently incorrect. Colowyo's ponds are currently <br />designed to automatically dewater. <br />Colowyo continues by saying "...relief under the alternate limitations provision shall <br />be available to the extent required to regain the necessary l0-year, 24-hour capacity." <br />Colowyo's ponds are designed to pass and treat the l0-year, 24-hour event, not contain <br />it. Therefore, manual dewatering to "regain the necessary capacity" isn't necessary. <br />11. On Page 7 of their September 30 memo, Colowyo proposes changes to the proposed <br />sampling frequency. DMG believes that each and every manually-operated discharge <br />should be sampled and analyzed to demonstrate compliance with primary effluent <br />limitations. <br />In Part I.C.B., "Quarterly measurement frequency", the terms "continued" and <br />"intermittent" are used, but not defined. If a discharge occurs within the first month of <br />a quarter and lasts For three days, is that an "intermittent discharge", or a "continual <br />discharge"? We would assume its an "intermittent discharge". If we assumed <br />incorrectly, what is the difference between "intermittent" and "continual" discharge? <br />There should also be some distinction made between "intermittent automatic discharge", <br />"continuous automatic discharge", "intermittent manual discharge", and "continuous <br />manual discharges". We again believe that each and every manually-created discharge, <br />regardless of its length of time, should be sampled and analyzed for compliance. <br />