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Comments Submitted by Denver Water <br />August 20, 2010 <br />degradation of water quality and is inconsistent with the WQCD's standard procedure to <br />prevent further degradation. <br />5. WWQBEL Determination/Calculation. The mass balance equation in Section VI is <br />appropriate for a single point of discharge. Consider the appropriateness of this equation <br />for the multiple points or areas of discharge. The values of M? in Table A-8a would be <br />different if there were additional terms in the mass balance calculation incorporating <br />pollutant loadings from the mine pool, seeps, and waste rock pile areas. If WQCD <br />believes that information does not exist to expand the terms of the mass balance, it would <br />be appropriate to require the permittee to acquire this information and submit it in <br />response to a compliance schedule requirement incorporated into the permit. <br />6. Anti-degradation Evaluation. Neither the permit limitations in place as of September 30, <br />2000, or the recent water quality assessment and permit development process correctly <br />account for the fact that mine pool, seeps, and waste rock piles contribute pollutant <br />loading. The use of permit limitations in place as of September 2000 as a baseline for <br />anti-degradation is questionable now that the reclamation approach is recognized as being <br />inadequate or having failed. The entire anti-degradation evaluation needs reconsideration <br />given that there are new and increased impacts that are obviously impacting water <br />quality. <br />7. NILs. The proposed zeolite based ion-exchange groundwater treatment system is <br />substantially different from earlier wastewater treatment facilities (WWTF) and should be <br />considered a "New Facility" treating a new source. The new source is groundwater and it <br />is not related to the production of uranium ore. <br />8. NILs. The direct conversion of pCi/L to ug/L for uranium is to divide by a factor that is <br />typically on the order of 0.65 to 0.70 but varies with radionuclide speciation. Guidance <br />on this conversion can be obtained from analytical laboratories familiar with radionuclide <br />analysis.