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<br />1, Coldwater segment with table value standards. There are no site specific standazds so that any <br />instream increases in metals concentrations must meet table values. If [he mine proponents <br />predict ins[ream metal concentrations will increase, an adequate monitoring program is needed <br />along with contingency plans to limit metal increases to those allowed by the existing stream <br />standazds. Table 2.05.6-8 of the Lorencito application predict that [he worst case iron <br />concentrations at the PRS-3 (The Purgatoire River downstream of the mine) would increase from <br />0.44 to 2.14 mg/l. Past DOW experience indicates that at an 2.4 mg/I iron concentration other <br />metals (specifically cadmium, copper and zinc) are typically present in levels either acutely or <br />chronically toxic to aquatic life. <br />The application needs to address the issue of reduced trout numbers due to increased <br />metal concentrations. Stream standards are set to protect trout populations. If the mine meets the <br />existing stream standards for this Purgatory River segment there should not be adverse impacts <br />to the brown trout population. <br />3. Detection limits for water quality analvses The application indicates that certain water <br />quality parameters were present at levels less than detection limits. These metals include silver, <br />copper and mercury. The surface water quality detection limits listed in various sections of the <br />application indicated that all water analyses were performed by ICP analysis. ICP detection <br />limits are often higher than ecologically pertinent concentrations. For example, the copper ICP <br />detection limit is 10 parts per billion. A copper level of ] 0 parts per billion can be lethal to trout. <br />Consequently, it is imperative to determine the copper concentrations in surface water a[ levels <br />lower than those produced by ICP analysis. Other mines and municipalities throughout Colorado <br />employ laboratory procedures that produce accurate, replicable data at concentrations far less <br />than ICP results. The DOW requests that the applicant use the following laboratory protocols <br />and detection limits: <br />Parameter method detection limit <br />cadmium graphite furnace 0.1 parts per billion <br />copper 1.0 parts per billion <br />zinc flame as 10 parts per billion <br />selenium graphite furnace 2 parts per billion <br />silver 0.05 parts per billion <br />nitrite calorimetric 3 parts per billion <br />7'he applicant needs to begin collecting water quality data using these, or other, appropriate <br />techniques that produce the same, or lower, detection limits. <br />The DOW requests the inclusion of selenium into the suite of parameters monitored by <br />the applicant. Selenium is an issue on the entire Arkansas River Basin. The dazk shales referred <br />to in the application are an indication that selenium levels may be an issue in Lorencito Canyon. <br />4. Decreased water quali[v in Lorencito Canvon and the Purgatory River The application <br />indicates that the water quality in Lorencito Canyon will be "decreased." This degradation will <br />also result in deceased water quality in the Purgatoire River. The application also indicates that <br />