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i <br />continuing with the Division's Order to sample and analyze <br />MDGE-1, CCS-1, CCS-2, PRS-2 and PRS-3 at 14 day intervals is not <br />warranted and WFC requests this sampling requirement be <br />eliminated. <br />As an alternative WFC proposes to conduct two additional <br />biomonitoring studies to confirm the non-toxicity to aquatic life <br />to Pond 002 effluent. These studies will be conducted within the <br />next two months as the mine water system is evaluated and <br />modified under the Division's Order. Biomonitoring will be <br />coordinated with the mine water handling system demonstration <br />program required by the Colorado Department of Health. NALCO <br />7883 (an aluminum sulfate based flocculant) may be used during <br />this demonstration project. <br />WFC further requests an extension to June I, 1988 of the <br />abatement date for Step 2, submittal of a technical revision <br />describing the mine water handling system. Per our recent <br />discussions, WFC has agreed to provide the Division with a <br />complete technical revision for construction of ponds 005 and 006 <br />without chemical treatment. This revision, if approved, would <br />later be modified to allow addition of chemical treatment if <br />deemed necessary. <br />With respect to the "Operation to be Ceased Immediately" and <br />the "Affirmative Obligation to Abate Imminent Danger or Harm" <br />specified in the Order, WFC requests that the interim use of <br />NALCO 7883 be approved during the mine water handling <br />demonstration program required by the Department of Health, since <br />this demonstration program may be conducted before final <br />processing of the technical revision required by Steps 2 and 3. <br />Thank you for your consideration in this matter. <br />Sincerely, <br />David M. Stout <br />Environmental Coordinator <br />DMS/cah <br />cc: Mike Kolin <br />