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A.J. Waldron Febrciary 17, 1995 <br />Re: 1993 and 1994 Annual Hydrologic Reports <br />Even if SMC were to install an expensive gauging station at both <br />NF-1 and NP-2, the difference in flow would probably not be <br />significant. Values from the USGS are reported to the nearest <br />cfs. Values for the floc-~ in the North Fork of the Gunnison at <br />the gauging station are from a lowest daily mean of 17 cfs on <br />?\'ovember 10, 1950 to a highest daily mean of 7,080 cfs on Nay 24, <br />1984, with 90 percent exceeding 52 cfs. <br />While there is a difference in quality between NF-1 and NF-2 <br />daring the low flow period of September to December, the question <br />is whether this is a significant difference. In the absence of a <br />lengthy str.tistical analysis, I would reference the conclusion of <br />the recentl}• completed Aquatic Impairment Study of the Sanborn <br />Creels "tine Discharge, Somerset, Colorado submitted by John C. <br />Emeric'.c, Nevis E. Coo::, and Susan +1. Hoffineister of the Division <br />of ;:nvironmcntal Science and Engineering, Colorado School of <br />5vines, copy of the abstract page enclosed. <br />Station XF-2 is within the detectable plume region downstream of <br />Sanborn Creek, "with the water quality returning to ambient <br />conditions 600 meters downstream or less." The report was <br />submitted to Lhe Colorado Department of Health, Water quality <br />Control Division on Februar>• 1, 1995, with copies to the U.S, <br />Environmental Protection Agency and the Colorado Division of <br />Minerals and Gcolo „y, copy of the transmittal letter enclosed. <br />S?IC cannot chan;;e what has occurred in the past. However, we can <br />change the future within our control. k'e are currently in <br />compliance with the ~aonitoring Program, and we intend to remain <br />so. For the Division to pursue enforcement action for missing <br />monitoring valuos from 1993 and early 1994 would be to ignore the <br />progress made to date, an action not justifiable or reasonable. <br />It would, in fact, be counterproductive, and be another example <br />of the tactic of requiring the submission of self-ir.criminatin; <br />evidence by those presumed guilty until proven innocent. <br />Sc1C is willing to supply meaningful information as a result. of <br />the required monitoring program. However, the justification and <br />reasonable effort required for obtaining the data is not always <br />clear. SMC will ma!;c its best effort to comply, but I personally <br />am not willing to obtain the data at any and all costs, up to and <br />including the cost of a human life. <br />In req~_rds to M;•. Gor~iam's conclusion that the groundwater wells <br />have been c•andalizcd on the basis of data contained in the <br />hydrologic reports, I e,rould suggest that Mr. Gorham accompany you <br />on your next field inspection. You are both welcome to <br />physically inspect the steel-cased monitoring wells, the heavy <br />steel security caps, bolts, and loc!a. After the inspection, and <br />n <br />