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<br />• <br />htr. William Agnew - 3 - June 7, 1990 <br />Well GF-7 - It is our opinion that the approved plan should remain <br />in effect for this well. Ash disposal in this area of <br />the mine is fairly recent, and more data will be <br />required prior to allowing a monitoring reduction at <br />J this site. <br />Well GF-11 - The comments provided for Well GF-3 apply to this <br />well. Please address the same issues for Well GF-11. <br />(.~ux Well - We strongly recommend that Trapper continue monitoring this <br />well as already required. We cannot approve this reduction <br />request at this time. <br />~ffadium 226 - This request is acceptable. The state standard for Radium <br />226 in surface waters is 5.0 pCi/L. <br />Section 2.9.2 - Parameters Modifications <br />J1. The request to analyze metals in the surface water samples by the Total <br />Recoverable method is consistent with the existing "Classifications and <br />Numeric Standards for Lower Colorado River Basin (3.7.0)", with two <br />exceptions. <br />Please revise your request to show that all metals will be analyzed by <br />the total recoverable analyses, except iron and manganese. To be <br />consistent with the existing stream s andards for the Yampa River, iron <br />and manganese should each be analyzed for both the total and soluble <br />analyses. Specific methodology definitions are provided in the Colorado <br />Department of Health Water Quality Control Commission, "Basic Standards <br />and Methodologies for Surface Water" publication (effective September 30, <br />1989). <br />The Department of Health has advised us that, eventually, all stream <br />standards wi17 be measured against the dissolved analysis as defined in <br />the above-referenced document. The change in methodology will occur on a <br />basin-by-basin basis. The standards for the lower Yampa have not yet <br />changed; however, the Department of Health recommends that operators <br />begin analyzing surface water samples by both the dissolved and total <br />recoverable methods. We recommend that you consider this option; <br />however, it is not required at this time. Such a requirement may be <br />J considered when the Yampa standards change. <br />2. Please provide an updated page 4-241d, which shows the analytical method <br />associated with each parameter analysis. <br />Section 2.0 - Miscellaneous <br />Please provide an updated page 4-241b which shoes the East Pyeatt monitoring <br />location as an NPDES monitoring site. <br />- Lux Aaol <br />ank you for the above-referenced submittal. <br />