Photograph Attribution: Public Domain, Steve Marterano/USFWS. Jeff Freund at Coleman National Fish Hatchery scoops winter-run Chinook salmon on March 2 before they were trucked to Battle Creek later that morning. Approximately 29,000 salmon were released into the North Fork of Battle Creek, a tributary of the Sacramento River where they once thrived. The fish are from the Livingston Stone National Fish Hatchery captive broodstock program. 

                                            Introduction

The Leadville National Fish Hatchery seeks to renew the NPDES Permit. The purpose of this permit is to establish discharge limitations for wastewater from the Hatchery wastewater treatment facility to an unnamed tributary to Lake Fork. There were several sections of the statement of basis and the draft permit that were committed on: Technology Based Effluent limitations (TBELS), major changes from previous permit, Description of Discharge and Monitoring Points and other facility history.

Qian Zhang

United States Department of the Interior
Fish and Wildlife Service
Leadville National Fish Hatchery
2846 Highway 300
Leadville, CO 80461

Telephone: (303) 312-6267

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Re: Proposed Draft NPDES Permit No. CO-0000582 for the Leadville National Fish Hatchery Comments Due 3-28-2022

Dear Mr. Zhang,

Environmental Review, Inc. has reviewed the draft permit no. CO-0000582 and has the following comments:

1)    Statement of Basis, Section 2: Major Changes from Previous Permit (Page 6) & Section 6.1 Technology Based Effluent Limitations (TBELs) (Page 10): The permittee has made changes in the proposed permit regarding the monitoring requirements of total phosphorous and total nitrogen stating that from the review of Table 1: Summary of the DMR Data between January 2017 to June 2021 for Outfall 001, the highest detected concentrations of total phosphorous and total nitrogen were well below the annual median values for total phosphorous and total inorganic nitrogen limitations for Non-Domestic Wastewater Treatment Works provided in  Colorado Regulation 85 - Nutrients Management Control Regulation (adopted 6/11/12,  effective 9/30/12) and hence there is no reasonable potential to affect water quality. Table 1 also reveals that a total of 8 data points were collected between January 2017 to June 2021 to get the concentrations of total phosphorus and total inorganic nitrogen. However, the Code of Colorado Regulation 85 Section 85.6 (2)(b)(i)(C)[1] states that the frequency of sample collection shall be done a minimum of six times a year for minor discharges and monthly for major discharges. This means a minimum of 21 data points for each of the nutrients only can be considered as meeting the monitoring requirements. Thus, a total of 8 data points for each nutrient is insufficient data to conclude there is no significant deviation from water quality standards.  

2) Draft Permit, Section 2, Description of Discharge and Monitoring Points, Table 1 (Page 8): The Permittee has provided the coordinates for the point of discharge, Outfall 001 yet, the Permittee has not provided a map or an aerial view of this location showing the area and the surrounding where the permit is being applied. Having an aerial view or a photograph of the point of effluent discharge can help identify potential environmental hazards or impacts at that point. The Statement of Basis submitted along with the draft permit did not include any aerial views or photographs of the point of effluent discharge.

     3) Statement of Basis, Section 2: Major Changes from the Previous Permit (Page 6): The Permittee has stated that the monitoring requirement for pH has been removed from this Permit and yet, there is no reasonable clarification and/or data given for this change being made.

      4)  Statement of Basis, Section 4.2: Other Facility History (Page 6): The Permittee has stated that during the last EPA inspection in September 2014, the Leadville National Fish Hatchery was required to flow proportion TSS samples and the Hatchery was not in compliance with this requirement. The Hatchery was also required to submit a Standard Operation Procedure to flow weight the composite samples. Has the Standard Operating Procedure been submitted? Have these requirements been met by the Hatchery to be in compliance? Information about these compliance requirements needs to be clarified through field reports or other substantial documents.

   5) Statement of Basis, Section 6.1 Technology Based Effluent Limitations (TBELs) (Page 10): The Permittee has stated that Best Management Practices (BMPs) are being applied to the Hatchery. In-depth plan and specific details about the BMPs that the Permittee has devised for the Hatchery has not been attached to the draft permit. A thorough and detailed BMPs is required in the absence of numeric Technology Based Effluent Limitations (TBELs) to control the chemical concentration in the discharge.

6   6)The first paragraph of section 11.1 titled Biological Evaluation claims that “This Hatchery discharges to an unnamed tributary to Hunt Gulch and into Lake Fork, a tributary to the Upper Arkansas River.  Limits established in this Permit are protective of aquatic life.” (pg. 18).  Does the tributary have no name or is it not being named in the document?  If no name exists, it may be helpful to add an it may be helpful to add a description of the tributary for public transparency.

     7) In section 11.1, it is claimed that total suspended solids from fish waste and uneaten food are anticipated to be settled into ponds before discharging.  Additionally, in section 6.2.1 titled Pollutants of Concern, it is stated that “EPA has determined that continued monitoring of dissolved oxygen at this Hatchery is not otherwise subject to Colorado Regulation 32 and is not required to meet water quality-based requirements. Requirements for dissolved oxygen data collection have been removed from this Permit.”  Could releasing fish waste into this body of water contribute to algal blooms?  If so, If so, would it not be wise to continue monitoring dissolved oxygen? 

When responses to these comments are available, kindly email them at the at the earliest to us at This email address is being protected from spambots. You need JavaScript enabled to view it., This email address is being protected from spambots. You need JavaScript enabled to view it. and This email address is being protected from spambots. You need JavaScript enabled to view it..

Thank you,

Kazie Douglas (Associate in Colorado)

Environmental Reviewer

Namratha Nallappan, E.I.T. (Associate in Utah)

Senior Environmental Reviewer

Matthew Coughlin (Associate in Maryland)

Review Coordinator

Environmental Review, Inc.

1792 Rogers Avenue

San Jose, California 95112 

www.envreview.org

(a 501(c)(3) Nonprofit Public Benefit Organization)