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Using the water quality standazds for agricultural use as the performance standazd and reclamation goal would require improvement from existing conditions, without an unrealistic goal of total cleanup. In order to use performance standards, the reclamation plan must include a monitoring plan. Monitoring of surface water would need to occur through the yeaz to define changing conditions. Monitoring results should be tied to the performance standards, so that ifmonitoring shows zinc levels above the standazd, additional reclamation can be planned. Other Comments The reclamation plan refers to Windy Gulch as an ephemeral stream and references the Water Management Consultants', December 1999 "Windy Gulch Assessment" as the source for that finding. The Water Management Consultants report refers to Windy Gulch as an intermittent stream, which would be correct. There is a big difference between the two, as intermittent streams have a groundwater component. Windy Gulch has a substantial groundwater flow component. The reclamation plan (and the 1999 Windy Gulch Assessment) state that metals in Windy Gulch may come from natural sources, from the waste rock piles or from both. No data or evidence is presented to document the possibility that the metals come from natural sources. The most likely sources of contamination aze the mineralized waste rock dumps located in the bottom of the Windy Gulch drainage. Movement of metals over the years from these dumps would have contaminated Windy Gulch alluvium below the dumps. It would seem very difficult now to demonstrate that metals in the Windy Gulch alluvium have come from anything other than the dumps. In addition, some of the data provided by the 1999 Windy Gulch Assessment (Water Management Consultants) suggests that natural sources aze not the cause. HW-1 and HW-2 are shallow bedrock wells located just above the 9360 dump. HW-1 was completed in the Creede formation east of the Windy Gulch channel and HW-2 is located adjacent to the channel HW-1 would be more reflective of natural Creede formation conditions than HW-2 and yet HW-2 has higher levels of contamination. Another piece of information that would direct our attention away from natural sources is the data provided by drive points in Windy Gulch. DP-1, above both dumps has good quality water. DP-3 and DP-4 below the 9700 and 9360 dumps, respectively, indicate relatively high metals. DP-5, still in Windy Gulch alluvium, but further from the dumps has better water quality. The only natural portions of Windy Gulch alluvium, separated from the mine dumps, have either good quality water or improving quality with more distance from the dump sections. There has been discussion about the accuracy of flow predictions for different flow events in Windy Gulch. Homestake's plan uses 14 cfs for the 5-yeaz flow and other work