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For the first time since testing for fluoride began, Park Center has received two <br />secondary violations, one in 2006, one in 2007 for fluoride levels. We have joined the <br />Riverwatch Program so that we may continue specific site testing for both metals and <br />fluoride to see if there is any connection or if gold mining has any influence on fluoride <br />levels. In 1994, shortly after the reopening of the gold mine, Park Center's fluoride level <br />was at 1.2 mg/l. The last two years the fluoride level has risen to 2.2 and 2.1. The <br />secondary level for fluoride is 2.0, so the District has had to issue fluoride warnings to <br />it's constituents for the past two years. CC&V was contacted to see if they had made any <br />changes which would affect fluoride levels They did promptly reply with test results <br />showing the ambient testing is high as well, although they noted that testing for fluoride <br />was not within the parameter of their permit. The District will be required to remedy the <br />high fluoride levels to avoid further violations. <br />On it's website, CC&V notes that "water quality is regulated by two separate <br />agencies," which on the surface would make one feel secure. Surface water is regulated <br />by the Water Quality Control Division of the Colorado Department of Health, and the <br />mine, as an active part of its permits, does all of the required testing and inspections. <br />What the mine does not tell you is that CC&V Mine has been successful in getting certain <br />contaminant levels adjusted for ambient and site specific standards. What this means is <br />that due to the fact that historical mining has already impacted the water quality, and <br />since CC&V is a zero discharge facility, adjustments have been footnoted for constituents <br />like manganese and sulfates. Federal and EPA regs do not have to be adhered to on <br />these items, and Park Center Water District is left alone to deal with these higher levels. <br />In 2006, the WQCD proposed `the adoption of the Water Supply Use <br />Classification" for Upper Arkansas Segment 21, which CC&V opposed. The water <br />quality assessment for the Carlton Tunnel completed in 2005 listed the following <br />"Pollutants of Concern": Total Recoverable Arsenic, Dissolved Cadmium, Dissolved <br />Chromium VI, Dissolved Copper, Free Cyanide, Total Recoverable Iron, Dissolved Lead, <br />Dissolved Manganese, Total Mercury, Dissolved Nickel, Dissolved Selenium, Dissolved <br />Silver, Dissolved Zinc. " However, in 2007 in a Sur-Rebuttal Statement, WQCD stated <br />that "The Commission has determined that it is not appropriate to add a water supply <br />classification to either of these segments at this time. The evidence submitted does not <br />demonstrate an immediate threat to either water supply...". Park Center Water District <br />would like to see that it never becomes an "immediate threat" to our users. We would <br />prefer being proactive rather than reactive for the health and well being of our <br />constituents. The Division recommended that Park Center continue to monitor for <br />sulfates at our intake, which we do, but we believe that CC&V mine should take the <br />initiative to assume some responsibility for the mining industry's affect on Colorado's <br />water supply. <br />We believe that a pro-active partnership between CC&V mine, who is profiting <br />from the mining activities, and the Water District, who is paying the exorbitant costs to <br />treat the results of mining activity, would be of great benefit to users of Fourmile Creek <br />waters. There are practical and feasible treatment techniques available to improve the <br />Fourmile Creek water quality. Flow augmentation to provide adequate dilution or <br />proportional pre-treatment of Carlton Tunnel discharge would provide a significant <br />remedy for the District's treatment problems. Upstream users should not threaten or <br />degrade water quality for downstream users.