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• -3 • 3. Rule 2.05.6(3)(b)(ii) - The applicant has included a description of the runoff and sediment control system that would be used to meet the normal effluent limitations (TSS, Zron, Manganese, pH). However, the Colorado Department of Health has established additional numerical standards for 27 water quality constituents (attached) for all tributaries in the Trout Creek drainage. Since Foidel Creek is an intermittent stream, the effluent itself should meet these standards. The applicant should demonstrate that effluent from the mine site would meet the specific numerical limitations or provide a plan for treatment of the effluent for those standards which are exceeded. (The Division is particularly concerned with the discharge of water from the mine workings and from the spoils dewatering well in Section 27.) 4. Rule 2.05.6(3)(b)(iii) - The applicant has submitted a surface water monitoring plan (Exhibit ZO). A preliminary review of this plan has identified several concerns. The applicant would be using an existing U. S.G.S. monitoring station as its. upstream monitoring station of Foidel Creek. IE is certainly appropriate to use this station. However, the applicant should commit to establishing its own upstream monitoring should the U.S.G.S. discontinue this station. Exhibit 10 refers to Fish Creek rmnitoring stations 1001 and 1002, while Map ~9, the Baseline Hydrology Map, shows one station, CYCC Station 26. Either the map or the text should be revised to be consistent. Also, the map should show both the upstream and downstream stations on Fish Creek. The applicant's proposed effluent water quality monitoring should be expanded to include those water quality constituents for which the Colorado Department of Health has established numerical stream standards (attached). These constituents should also be added to the stream monitoring stations on Foidel Creek, and monitored on a quarterly basis. The Division may have additional adequacy concerns with respect to surface water monitoring after reviewing the applicant's revised discussion of probable hydrologic consequences. 5. Rule 2.04,7(3) - The adequacy of this section, Alternative Fla ter Supply Information, will be reviewed after the Division has reviewed the applicant's revised discussion of probable hydrologic consequences. This completes my preliminary adequacy review of the surface water sections for this mine. Next week I will make preliminary AVF determination, and , prepare a memo concerning the adequacy of the alluvial valley floor sections of the permit application. ,~~ /ep cc: Ed Bischoff Jim Pendleton Dave Craig Bob Liddle