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Requirement <br />Regulation <br />Reviewed <br />Comment <br />After mining is completed, Trapper's surface water will be <br />used in the former mine permit area for watering livestock <br />and wildlife. The suitability of Trapper's surface water for <br />those uses is evaluated by comparing the surface water data <br />supplied in the AHR to the water quality standards in <br />CWQCC Regulation 31 and Regulation 37 for stream <br />segment 3b. Regulation 37's classifications for stream <br />segment 3b include Aquatic Life (warm 2), Recreation (P), <br />and Agriculture. The State of Colorado has defined the <br />Agriculture classification of water as suitable for irrigation <br />as well as stock watering. It is assumed that water that is <br />safe for livestock and aquatic life is also safe for wildlife. <br />Also, certain constituents monitored have effluent <br />limitations standards required from Trapper's NPDES <br />permit. NPDES monitoring results are also reviewed and <br />discussed in section E. and G. above. <br />Water quality was measured at the downstream discharge <br />points in drainages (near the permit boundary), and it is <br />assumed that water quality at these locations is also <br />representative of water quality at higher points in the <br />L. Prevention of <br />watersheds. It appears two exceedances of the standards set <br />impacts to <br />CDRMS <br />forth in Regulation 31 and 37 occurred. One parameter is <br />surface water that <br />regulation <br />Comment <br />approaching the standard. <br />adversely impact <br />4.05.1(2) <br />the postmining <br />• Johnson Gulch; Pb(t) level on 1/2/2013 was <br />land use <br />reported to be .11 mg /1 this is higher than the 100 <br />ug /1(1 mg /1) chronic Reg. 37 standard for Pb for <br />this stream segment. The level dropped to .04 mg /1 <br />on October 8, 2014. <br />• No Name; Pb(t) level on 1/2/2013 was reported to <br />be .11 mg/1 this is higher than the 100 ug /1(.1 <br />mg /1) chronic Reg. 37 standard for Pb for this <br />stream segment. The level dropped to .04 mg /1 on <br />October 8, 2014. <br />• Middle Flume; Manganese was reported to be. 197 <br />mg /1 on October 8, 2013. The Table III basic <br />standard for surface water with an agriculture use <br />is 200 ug /1(30 day) or .2 mg /1. The manganese <br />level for the drainage is approaching the standard. <br />It is unclear at this time what is causing the exceedances at <br />Johnson Gulch and No Name. The levels dropped below the <br />standard with the next sample. Trapper will need to monitor <br />these sites and constituents further. <br />Page 3 <br />