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January 9, 2003 <br />I'aga 3 <br />Company does not have any mare recentwater quality data on these stream segmemts than that which <br />was submitted to•the Commission. <br />EPA submitted data from 1994 that includes metals values that were cwllaeted by EPA as part <br />of a CERCLA recormaissance study. Ahhough the metals valtus do exceed the table value standards, <br />EPA has not listed this area for Superfimd nunediation. We believe this supports the Commission's <br />1997 finding that the high ambient levels are either natural ar iacverrsr°blemun-Induced. If EPA now <br />disagrees with this fmcling (which it previously agpmved), it should present evidence at the next <br />Grmaison Basis hearing. <br />We note that this data was in EPA's possession well before the development of the 2002 303(d) <br />List To our Imowledge, this data was not "readily available data." We question why EPA did not' <br />present this data e:eriier when the List was developed by the IJivision, or subsequently, at the <br />September 2002 hearing on the 303(d) List We believe it is inapptopdate for EPA to submit this data <br />aRer the heaaag. <br />It is our understanding that EPA has expressed concern that the ambierrt water quality in these <br />segmentshas deteriorated. However, we want to point out that different statistical. methods were used <br />to calculate the ambient values in 199T and 2001. We believe That this difference in methods is largely <br />responsible for the different ambient vahres. <br />In conclusion, Climax wishes "to note that the Mt. Emmons mine discharge into Segment 12 <br />significantly dilutes the metals levels in Segment 12. It's cadmium discharge ranges between 0.3 µg2 <br />and 0.9 µg/L, (TVS = 5.4) and ambient = 2.6µg2, and its zinc discharge ianges between lielow <br />detection and 40 µg2 (TVS =325 µg(L) and ambient = 598 µg/L. <br />Climax believes the Commission acted properly and in accordance with ifs Listing <br />Methodology in placing Segments 11 and 12 on the Monitoring and Evaluation List, instead of the <br />303(d) List Ifyou have any questions or if you believe a meeting would be nse£ul to resolve any <br />remaining issues, please call me. <br />Sincerely, <br />VRAI~SH arm ItAISCIi, iar <br />~~y v~'xais~ir <br />JWR:keb <br />cc: Phil Hegeman <br />Anne Beierle <br />. Bryce Romig <br />Dan Kravets <br /> <br />