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.~. A~+ ~t„~~~.i- B <br />., ,.~ <br />II;B'!e,r~r!;!i!!I~,m~~~ CF&I STEEL CORPORATION <br />~ ~~ ~I~ ~' ~ A subsidiary of Crane Co. <br />i p <br />~!~~6mI1~I~~N~. dl!,~ P.O. Box 316 <br />STEEL <br />® Puchlo, Colorado R1002 <br />April 27, 1982 <br />Mr. Roy L. Cox <br />Hydrogeologist, Geochemist <br />Mined Land Reclamation <br />Colorado Department of Natural Resources <br />1313 Sherman Street ,'Room 423 <br />Denver, Colorado 80203 <br />Dear Roy: <br /> <br />~`J~',i U i~ ic~"~ <br />o_ <br />~,~ ,. <br />I appreciate your making time available to me on April 23, <br />1982, to examine your reasons for proposing the. water quality <br />monitoring program contained in your memorandum to Susan Mowry <br />of April 8, 1982. Our discussion of your reasoning.prepared me <br />to better address your concern for an appropriate finding that <br />CF&I is in compliance with other state and federal <br />regulations. Your attempt to find CF&I in compliance, in light <br />of the recent standards promulgated by the WOCC for the <br />Purgatoire River system, presents a dilemma for both of us. <br />As I related to you, CF&I .participated in the <br />classification and standard setting proceedings. On January <br />6, 1981, CF&I offered testimony and data before the Colorado <br />Water Quality Control Commission to assist the Commission in <br />its better understanding of the "ambient" conditions of the. <br />Purgatoire River. Water Quality Control Division members <br />chose, for the first time, to raise the issue of comparability <br />of analytical data for "total" metals. Our data was rejected <br />from the standard setting data pool on the grounds that the <br />samples were rigorously digested and did not compare with <br />Colorado Department of Health data subjected to a lesser <br />digestion procedure. The consequence, of course, to the <br />discharger is that samples required for NPDES compliance must <br />be more rigorously digested than were the samples on which <br />standards were derived. <br />In your effort to find CF&I in compliance, you are <br />comparing rigorously digested samples as baseline with lesser <br />digested values, pseudo-statistically manipulated to reflect <br />even lower va).ues which were promulgated as standards. The <br />entire standard setting prooess has been consciously conducted <br />to bias standards toward lower concentrations. <br />