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MR. ROBERT J. SHUKLE CDPS N0. CO-0027154 OCTOBER 3, 1485 PAGE 3 impede the progress of fine particles drifting across the upper waters of the pit. CYCC is implementing the sampling program recom- mended by Applied Hydrology Associates. Results should be available by the end of October and will be forwarded to you by November 8th. If results indicate that baffles will be effective in reducing metal contributions to Pond D, baffles will be installed. The following considerations provide additional assurance that the above measures will be adequate. 1. In the past, discharge limitations have been imposed far total metals. The proposed new discharge limitations set forth in Table I of your August 29 letter have the same numerical limits, but the limitations are for total recoverable metals rather than total metals. CYCC supports the proposed change to a total recoverable standard. As illustrated in Table 4, CYCC believes it will be able to meet the proposed total recoverable limitations. 2. Previously, it has been thought that high zinc concentrations were a concern at Discharge Point 005. However, the high zinc concentra- tions which have been reported apparently do not actually exist. CYCC has recently learned that its testing laboratory, Bookcliff as been com i ~ al tica err fi ures. Retesting of available sample splits has confirmed that zinc concentrations are not in ex- ceedance of present or proposed effluent limitations. Attached is a September letter from Bookcliffs documenting the analytical errors and results of retesting. 3. CYCC has petitioned the Colorado Water Quality Commission for a change in the water quality standards on which the proposed dis- charge limitations at both discharge points are based. The Petition is based generally on test results showing that for certain para- meters, ambient water quality will not meet the existing standards. It is anticipated that stream standards for certain metal parameters (most probably copper, iron, and soluble manganese) may be relaxed to better reflect ambient water quality. Pond F (Discharge Point 007) Prior to the Spring of 1984, Pond F and Discharge Point 007 (mine site 87) drained runoff from a reclaimed mining area. In approximately April, 1984, an artesian spring (site 114) appeared in the reclaimed area. After some discussion of alternatives, the water from the spring vas rou~;.i to Pond F, and an Application for an Amendment to the Discharge Permit was applied for. Samples have been taken at the spring and at the discharge point. In your letter of August 29, you take the position that the spring is a "new source" of mine discharge water. CYCC does not agree with the position,