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TDS twice during the 90 day monitoring period, it is appropriate to leave the "No <br />discharge" box unchecked. <br />Discussion <br />The quirk in the DMR's is that the quarterly reporting required for TDS only occurs in the third <br />month of the quarter and can be independent of whether there was a discharge occurring in that <br />third month. Such is the case here. Oxbow reported on the March 2012 DMR the TDS data for <br />the January and February discharges and there was no discharge in March. <br />To assist in clarifying this issue in the future, Oxbow has already begun to note on the letters of <br />transmittal accompanying the third month of the quarter DMR's where there were no discharges <br />for that third month, while still reporting the required quarterly TDS reporting for the previous 1 <br />and/or 2 months. <br />If you have any questions or comments, please contact me at (970) 929 -5806. <br />Sincerely, <br />k, <br />�ames A. Kiger <br />Environmental Manager <br />Attachments <br />Xc: Jim Cooper, OMLLC <br />Brock Bowles, CDRMS <br />Files <br />s Page 2 <br />