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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT, Water Quality Control Division <br />Rationale — Page 11, Permit No. C00036251 <br />RP Analysis for JD -7 Mine, Outfall 001A <br />Total Zinc <br />There were not enough data available to perform a RP analysis for total zinc, however, a qualitative <br />determination of no RP has been made due to the highest concentrated noted in the discharge vs. the <br />WQBEL. The Federal ELG limits of 500 /1000 µg/1 for 30 -day average /Daily maximum are more <br />stringent than the WQBEL for total recoverable zinc, and therefore will apply, effective <br />immediately. <br />Total Radium 226 +228 <br />There were not enough data available to perform a RP analysis for total radium 226 +228, however, a <br />qualitative RP have been made as the facility has had violations for total radium 226. The limitation <br />for total radium 226 +228 is based on the WQBEL of 5 pCi/1 for a 30 -day average. This WQBEL is <br />based on Section 31.11(2) of the Basic Standards and Methodologies for Surface Water to protect <br />the waters of the state from radionuclides chemicals. A 30 -day average limitation of 5 pCi /1 for total <br />radium 226 +228, has been included in the permit. This is the same limitation in the previous permit <br />and is effective immediately. <br />RP Analysis for JD -9 Mine, Outfall 002A <br />Total Zinc <br />The RP analysis for total zinc was based upon the water quality standards, which is the WQBELs for <br />total zinc. With the available data, the lognormal program was used to determine the appropriate <br />statistics to determine the MEPC. The MEPC was significantly less than half the MAPC of 2000 <br />µg/1 for 30 -day average. Since the RP analysis results in no RP, the Federal ELG limits of 500 /1000 <br />µg/1 for 30 -day average /Daily maximum for total zinc will apply, effective immediately. <br />Total Radium 226 +228 <br />There were not enough data available to perform a RP analysis for total radium 226 +228, however, a <br />qualitative RP have been made as there have been violations of the water quality standard. The <br />limitation for total radium 226 +228 is based on the WQBEL of 5 pCi /1 for a 30 -day average. This <br />WQBEL is based on Section 31.11(2) of The Basic Standards and Methodologies for Surface Water <br />to protect the waters of the state from radionuclides chemicals. A 30 -day average limitation of 5 <br />pCi /1 for total radium 226 +228, has been included in the permit. This is the same limitation in the <br />previous permit and is effective immediately. <br />4. Organics — The effluent is not expected or known to contain organic chemicals, and therefore, <br />limitations for organic chemicals are not needed in this permit. <br />5. Whole Effluent Toxicity (WET) Testing - WET testing is not required for outfalls OO1A, OO1B, <br />002A, 002B and 002C, since there are no aquatic life standards for this stream segment. However, <br />the Division reserves the right to reopen the permit to include WET testing, if new information (such <br />as the effluent making it to the Dolores mainstem) makes WET testing necessary. <br />