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<br />WeAem Fuels{olorado <br />P.o. Box 628 <br />Nucla, Colorado 81114 <br />Telephone 970/864-2165 <br />fu 970/8642168 <br />I I January 2002 <br />Ms. Carla Lenkey <br />Colorado Department of Health <br />Water Quality Control Division <br />Permits and Enforcement Section <br />WQCD PE-62 <br />4300 Cherry Creek Drive South <br />Denver, CO 80222-1530 <br />Dear Ms. Lenkey: <br />As we discussed on the phone last Tuesday, Western Fuels Colorado wishes to advise you that <br />our 4th Qtr 2001 Whole Effluent Toxicity (WET) test for discharge point NPDES 008 failed the <br />acute Ceriodaphnia portion of the test for water collected on 2G December, 200E Our lab, <br />Water & Environmental Testing (W.E.T.), [nc. of American Fork, UT, notified us on 31 <br />December, and so we resampled the outlet on 2 January, 2002 as per the Automatic Compliance <br />Schedule section of our permit. That sample failed a retest of the Ceriodaphnia as well. <br />• As I described to you, the water discharged from NPDES 008 is pumped out of a groundwater <br />sump located in the southern, downdip portion of our Turn Slot. The water, which is very clear, <br />is pumped out at a rate between about 100 gpm to about 500 gpm, depending on pump size and <br />dewatering requirements. This discharge is split roughly equally and piped to both the NPDES <br />008 and NPDES 007 ponds. Because of its clarity, the NPDES 008 water is manifolded directly <br />into the discharge barrel of Pond 008, while the waterto the NPDES 007 site is discharged into <br />the pond (Pond 007) behind it. Pond 007 has a surface area of about 4.2 acres and normally <br />Bolds water year round. TDS values for both the NPDES 007 and NPDES 008 WET tests are in <br />the, 4,000 mg/L range. The 4th Qtr 2001 WET test for Pond 007 (NPDES 007 outfall) passed. <br />During the summer irrigation season, Pond 007 water can come from both pit and surface <br />sources. However, during the latter part of the 4t1i qtr, Pond 007's sole source ofwater was from <br />the pil pump. Since this water passed its WET test and the NPDES 008 discharge waterdid nol, <br />something must occur in Pond 007 that does not occur during the direct discharge from [he <br />NPDES 008 outfall. <br />In an attempt to discover why, WPC has taken the following steps, and these steps are largely <br />based on conversations with Lcc Rawlings of W.L.T., Inc. and Chris Gates, of the Colorado <br />Department of Health; <br />I) Stopped discharging fromNPDGS008. Becauseourdischargepipingcurrently <br />has the capacity, we have transferred all of our pit water to the Pond 007 /NPDES 007 <br />outfall. This outfall will be monitored as per ourcurrent permit requirements. Because <br />there is no further water to test at NPDES 008, the accelerated WET testing has also <br />• <br />