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III IIIIIIIIIIIIIIII <br />999 <br />.. <br />MONTGOMERY WATSON <br />147 Pine Grove Rd Suite 109 <br />PO Box 774018 <br />Steamboat Springs, Colorado 80477 <br />Tel: 970 879 6260 <br />Fax: 970 879 9048 <br />To: Joseph J. Dudash <br />Colorado Division of <br />Minerals & Geology <br />Date: 7/7/99 <br />JUL 121999 <br />1313 Sherman Street -Room 215 <br />Denver, Colorado 80203 <br />(303)866-3567 <br />Subject: Oxbow Mining, Inc. - <br />Worst-Case WQ Evaluation <br />Division of Minerals 8 Geology <br />Reference: 1342821.0.1210800 <br />Via: Fed X UPS US Mail <br />Joe -Enclosed are three copies of the mass balance calculations for worst-case water quality <br />discharge conditions for OMI's proposed 2,000 gpm mine water discharge to the North Fork. As <br />indicated by the table, worst-case cumulative discharge levels would exceed the DMG's material <br />damage guidelines for domestic water supply and approach guideline levels for agricultural use <br />for TDS only. For all of the other parameters of interest, cumulative dischazge levels are below <br />water quality thresholds and mine discharge would actually tend to reduce naturally high iron <br />levels in the North Fork. <br />While these numbers may have some value relative to bracketing the potential for any adverse <br />water quality impacts, it is important to recognize the following to evaluate these numbers and <br />put them in the proper perspective: <br />1) The numbers reflect continuous mine discharge at the maximum 2,000 gpm rate, minimum <br />historical low flows, and are being compared against guideline levels (DMG Material <br />Damage Suspect Levels) that are very conservative and below corresponding EPA effluent <br />levels for similar uses. The probabilities of maximum continuous discharge and minimal <br />stream flows are both low, so the cumulative probability of these two conditions occurring <br />concurrently are similarly low <br />2) If stream flows are at such a low level that discharge from Paonia Reservoir is used to <br />maintain minimum in-stream flows, there would probably be some natural water quality <br />degradation (below the average quality values used) due to high TSS levels in the reservoir <br />and, as a short-term consideration, water availability would probably be more of a concern to <br />down-stream users than the limited potential changes in water quality indicated by [he worst- <br />case mass balance calculations <br />