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Comments Submitted by Denver Water <br />August 20, 2010 <br />ATTACHMENT C <br />Fact Sheet <br />1. Paragraph VI A (2)(d) regarding Colorado Mixing Zone Regulations: Denver Water is <br />of the opinion that the permittee is in possession of information that would support <br />CDPHE restricting the benefit of any calculated mixing zone, which supports the <br />exclusion from further analysis based on a fully mixed condition. There are at least four <br />sources contributing pollutant loadings: 1) the alluvial fill, 2) seeps in the alluvial fill <br />area, 3) the mine pool, and 4) waste rock piles. The collective impact of these pollutant <br />sources is that the entire stream width is impacted in the mine area and areas downstream. <br />2. Paragraph VI A (2)(g) regarding reasonable Potential Analysis: The outcome of this <br />analysis may change if comments below affecting BWQ or ADBAC concentrations are <br />incorporated. <br />3. Note that paragraph numbering/labeling is inconsistent and should be revised. <br />4. Paragraph VI A (8)(a) on page 14 regarding Economic Reasonableness Evaluation: <br />Denver Water disagrees with the WQCD's conclusion that this is not a new discharger.. <br />5. Page 15 regarding Special Reports. Due to the proximity of the mine to drinking water <br />reservoirs, Denver Water and other water providers need to be listed as a recipient of <br />special reports issued by the permittee in conditions of upset, bypass, or non-compliance. <br />Water Quality Assessment (WQA) <br />1. Introduction. The water quality assessment needs to reference the MLRB order for <br />treatment of mine pool water and the existence of waste rock (gangue) deposited in such