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2) Nitrogen speciation at the P & M site is unclear due to the current form of analysis of N02-N03. Please request that the lab report nitrite and nitrate separately and in addition, have them analyze for un-ionized ammonia in the surface water samples. Current NO2-N03 levels have occasionally exceeded the N03 standard of 10 mg/1 and frequently exceed the NO2 aquatic standard of 0.05 mg/1 and the domestic standard of 1.0 mg/1. The Division has not been able to ascertain the magnitude of the nitrogen problem associated with coal mines, due predominantly to inappropriate analytical testing. A surface mine adds nitrogen to the system during blasting and when fertilizers are used for reclamation. 3) The Division believes that water analyses from wells are contaminated by sediment which have no relationship to water quality in aquifer of interest. Thus, all ground water samples should be filtered with a 45 um filter immediately following sample acquisition and the analysis of dissolved parameters should be requested from the lab. Thus, it will no longer be necessary to monitor for total iron. 4) The Division, taking its lead from the Colorado Department of Health, is monitoring the total recoverable forms of metals in surface waters. This digestion is less intense than that for total analyses and many operators find that their waters consequently do meet the standards. As iron and manganese levels are high at the surface water sites and there are standards for both total recoverable and dissolved forms of these metals, the Division requests the modification of the HtdP to include both forms of manganese. 5) The aluminum standard is based on the soluble, or dissolved form. Please retain aluminum as a parameter in the surface water site complete list, but request that it be analyzed in the dissolved form. 6) Please prepare a plan to document and map spring discharges every April. Field parameters (pH, EC, temperature and flow) should be recorded at each seep, and P & M should prepare some criteria for full suite analyses at same sites. 7) Has P & M collected data which quantifies dewatering of the Wadge during pit development and its subsequent reestablishment? If not, P & M should prepare a plan which will address this issue and the performance standards of 4.05.11-4.05.73. Final Comments Please commend the operator on their submittal of an organized AHR. The graphs were very useful and the narrative provided a historic perspective on the hydrology at the mine as well as a cogent analysis of the water quality data. vjr cc: Sandy Brown 5276E