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i <br />Mike Boulay -41- April 11, 2011 <br />Please add specific information to the discussion that supports this <br />assertion. <br />CAM: Please see revised pages 2.05-50 & 51. <br />95. In Section 2.05.6(3)(b)(iv) on permit text page 2.05-58, it is stated that water <br />monitoring records will be maintained on site and submitted to the Division <br />annually. Please add that the discharge monitoring reports for the NPDES <br />permit will be submitted to the Division on a quarterly basis, as required in <br />Rule 4.13(2)(a)(iii). <br />CAM: Please see revised page 2.05-59. <br />96. In Table 2 - Surface Water, on page 2.05-57 of Section 2.05.6(3)(b)(iv), CAM lists <br />the analytes that will be monitored as part of the surface water monitoring plan. <br />The table indicates that all listed metal constituents will be analyzed as total metal <br />constituents. CDPHE receiving stream standards, however, require the analysis of <br />metal constituents as dissolved and/or total recoverable metals; depending on the <br />metal constituent and stream segment (the exception to this is mercury, which is <br />always analyzed as a total constituent). The analysis of a metal constituent using <br />the total metals methodology will, necessarily, yield an equal or higher <br />concentration than the analysis of a metal constituent using the dissolved or total <br />recoverable methodology. The use of a total metals methodology in baseline <br />analyses will, generally, yield higher concentrations of metals, the results of which <br />are not comparable to receiving stream standards. Please change the analytical <br />method for the metals analyses to either dissolved or total recoverable (or <br />both) as necessary in Table 2. If, however, CAM believes that the analytical <br />method should remain as total metals, please provide the Division with a <br />justification of why total metals analyses are valid and please describe how <br />the analytical results will be used in conjunction with the CDPHE receiving <br />stream standards. <br />CAM: Per email correspondence with Joe Dudash on March 11, 2011, it was decided <br />CAM will continue to monitor the parameters currently shown in Table 2. <br />97. In Table 2 - Surface Water, on page 2.05-57 of Section 2.05.6(3)(b)(iv), CAM lists <br />that chromium (Cr) will be analyzed. CDPHE receiving standards require the <br />analysis of both chromium III (Cr+3) and chromium VI (Cr+s). Please include <br />both chromium III (Cr+3) and chromium VI (Cr+6) in Table 2. <br />CAM: Table 2 has been revised, please see page 2.05-58 <br />98. Please add total hardness, flow, lab pH and lab conductivity to the list of <br />surface water sampling parameters in Table 2 on permit text page 2.05-57 of <br />Section 2.05.6(3)(b)(iv).