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Comments Submitted by Denver Water <br />August 20, 2010 <br />its current form, the discharge to Ralston Creek will result in the impairment of the water <br />body. This is due, in part, to the changed circumstances that have occurred, and the lack of <br />sufficient information upon which to currently determine whether the discharge will meet <br />applicable water quality standards. Because the issuance of the permit will result in an <br />impaired water body, the Division must first place Ralston Creek on the 303(d) list and <br />implement a TMDL for Ralston Creek. In addition, Cotter must show that applicable stream <br />standards are attainable considering pollutant loadings from each source. <br />Water Quality Assessment <br />The Water Quality Assessment ("WQA") could be challenged if not based upon an <br />accurate and contemporaneously filed permit application and other relevant information <br />such as the revised EPP. Cotter Corporation should be required to submit a new permit <br />application with all the requisite information described on the applicable application form. <br />The WQA needs to be revised to reflect pollutant loadings from each pollutant source <br />identified in the EPP (see Table 1 above and Attachment B) and to document the numeric <br />water quality values that form the basis for a determination of the adequacy of reclamation. <br />If reclamation thus far has not been based on numeric water quality standards, then a <br />compliance monitoring schedule for each pollutant source is appropriate for inclusion in the <br />permit. Over time, if pollutant loadings demonstrate that a contribution from a source is <br />low enough considering the collective loading, than this source is adequately reclaimed <br />relative to the water quality standard. <br />The WQA needs to describe any previous narrative, or numeric, reclamation <br />standards that DRMS has applied to each pollutant source or area of reclamation. Going <br />forward, this information is relevant to have a clear understanding of the reclamation <br />standards applied so that the adequacy of existing and new reclamation efforts relative to <br />water quality standards can be made, and if necessary based on monitoring results, be <br />revised to attain the water quality standard. <br />Permit Application <br />Cotter Corporation should be required to submit a new permit application with all the <br />requisite information described on the applicable application form. This is needed because <br />new reclamation strategies are being instituted, in part, to incorporate groundwater <br />remediation in response to inadequate or failed reclamation. It is reasonable to expect that <br />there be a permit application on file (submitted by the permittee) which contains a revised <br />Page 5 of 8