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Comments Submitted by Denver Water <br />August 20, 2010 <br />2. Part IB (1). On-site disposal of residuals and spent media, which were once proposed. <br />and may be still be considered as a reclamation strategy, should be prohibited because <br />ion exchange based processes are reversible and constituents may elude back into ground <br />and surface water. <br />3. Part IIA (12) regarding Submission of Incorrect or Incomplete Information and Part II B <br />(2) regarding Duty to Provide Information and Part II B (5) (b) (i regarding Permit <br />Modifications. The fact sheet, water quality assessment, and permit appear to have been <br />issued expediently without submittals or requisite application information from the <br />permittee that reflect the current partially reclaimed site, point and non-point sources of <br />pollutant loadings, proposed or existing treatment process schematics, incorporation of <br />methods or means to treat mine pool water, and other pertinent information. Denver <br />Water believes this information, which will change over time due to continued <br />reclamation, to be pertinent to the proper evaluation and determination of permit <br />conditions. Accordingly, Denver Water Requests that such information be named in a <br />compliance schedule and that a requirement to provide such information be established. <br />4. Part II B (5)(ix regarding technology based treatment requirements. Denver Water <br />understands that water streams containing radionuclides and other constituents can be <br />treated by a variety of treatment processes to attain concentration levels of all <br />constituents to below detection levels. Furthermore, radionuclide removal to below <br />detection limits is attainable by resin-based or zeolite-based ion exchange technologies. <br />Better performance is attainable through combinations of treatment technologies that may <br />include coagulation, filtration, anion ion exchange, cation ion exchange, or other physical <br />chemical treatment processes.