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• Division of Wildlife Issues and Responses <br />for June 5, 1997 Letter <br />(continued) <br />Water quality issues <br />A number of issues were raised by the DOW regarding overall water quality and impacts to the <br />surface water system and resident aquatic life. <br />Flathead chub <br />The DOW has expressed concerns that mining activity could impact the flathead chub <br />population identified in portions of Lorencito Canyon and the Purgatoire River. The <br />applicant responded that the control and treatment of discharges form the mining azea, <br />water quality monitoring and NPDES discharge monitoring (including Whole Effluent <br />Toxicity testing) should be adequate to protect resident chub populations. Discussions with <br />the DOW indicate that they believe actual, periodic population sampling is necessary to <br />determine the on-going status of chub populations. The DOW has verbally committed to <br />discuss this issue and respond with a recommendation toward the end of June. This issue <br />remains inadequate at this time. <br />• Response <br />It is believed that surveys to monitor the chub may result in mortalities [hat would impact <br />populations within Lorencito Creek and the Purgatoire River. Therefore, surveys for this species <br />are not proposed at this time. It is LCC contention that all known populations of the chub within <br />Lorencito Creek occur well upstream of any proposed mining disturbances, and would not be <br />impacted by mining. Also, water quality monitoring and NPDES discharge monitoring should be <br />sufficient to protect any populations occurring in the lower reaches of Lorencito Creek. Dilution <br />of any mine discharge within the Purgatoire River would be sufficient to protect populations within <br />the river. LCC would grant the DOW access to the mine property should they want to investigate <br />the chub population. <br />Brown Trout <br />The DOW has concerns based on past experience that iron concentrations of 2.4 mg/1 <br />indicate other metals (specifically cadmium, copper, and zinc) are present at toxic levels <br />to aquatic life. While no specifics were provided, the Division assumes that acid <br />conditions likely prevail under this scenario, causing the metals problem. The applicant <br />has presented baseline data indicating the concentrations of cadmium, copper, and zinc. <br />The Water Quality Control Commission determines effluent limitations as part of the <br />Colorado Discharge Permit System, based on steam classification and standards. <br />• Furthermore, the Division's experience indicates iron and manganese concentrations are <br />relatively high in coal basins, while pH levels are neutral to alkaline and other metal <br />concentrations are below the detection limit. Not withstanding, the Division believes that <br />5 <br />