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<br /> <br /> <br />~/ w <br />/: <br /> <br />2 <br />Notwithstanding the defective standards on which NPDES <br />requirements are based, the Water Quality Control Division <br />suspects only one "total" trace metal parameter (silver) from <br />CF&I's mines to exceed the arb}trary standard adopted by the <br />Colorado Water Quality Control;Commissi.on. <br />CF&I has tentatively agreed with the Colorado Department <br />of Health to collect monthly samples for silver for six months, <br />to be analyzed by a method comparable to the EPA prescribed <br />"total recoverable" technique and, at this moment intends to <br />insist the arbitrary standard (.0001 mg/1) be abandoned. We <br />intend to do no further trace element analysis than those <br />required by our NPDES permits. <br />I hope you will agree, as you have on two previous <br />occasions, that the buffering capacity of both our discharge <br />and that of the receiving waters indicate a minimal risk for <br />trace elements becoming dissolved to concentrations of toxic <br />concern. At our meeting in July, 1981, arranged for the <br />purpose of examining the results of our year long data <br />collection program for establishing baseline, we agreed that <br />trace elements should be .eliminated from further monitoring. <br />You felt only the salt load merited continued address. My <br />proposal, since Y.he dominant ions were identified and <br />established as reasonably consistent, was to measure the salt <br />load instrumentally and analyze only when anomalous readings <br />were apparent, Your counterproposal, because you felt the <br />chemistry at low and high Puragtoire River. flow was not <br />adequately defined, was to sample selected wells, the stream, <br />and the mine discharges during October and April. We agreed to <br />continue such a program for one year and again evaluate the <br />results. The substance of the monitoring program was again <br />confirmed during your visit to the mine sites in October 1981. <br />The program was initiated, is currently in progress and should <br />be ready for review in about one month. CF&I intends to <br />proceed with the program and present the data shortly in light <br />of your concern expressed. in our verbal agreement. <br />In the meantime, i expect you to examine for compa- <br />rability, the data base for your recent proposal against the <br />data base and statistical manipulation by which the recent <br />standards for the Purgatoire System were derived. Hopefully, <br />you will examine the January F, 1981, transcript of the record _ <br />of hearing for segment 5a of the lower Arkansas River and the <br />