2011-06-21_APPLICATION CORRESPONDENCE - C2010088

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Corey Heaps CAM Colorado LLC June 21, 2011 Page 52 CAM Response: Please see revised page 2.05 -59. Division Response: Response accepted. 96. In Table 2 — Surface Water, on page 2.05 -57 of Section 2.05.6(3)(b)(iv), CAM lists the analyses that will be monitored as part of the surface water monitoring plan. The table indicates that all listed metal constituents will be analyzed as total metal constituents. CDPHE receiving stream standards, however, require the analysis of metal constituents as dissolved and/or total recoverable metals; depending on the metal constituent and stream segment (the exception to this is mercury, which is always analyzed as a total constituent). The analysis of a metal constituent using the total metals methodology will, necessarily, yield an equal or higher concentration than the analysis of a metal constituent using the dissolved or total recoverable methodology. The use of a total metals methodology in baseline analyses will, generally, yield higher concentrations of metals, the results of which are not comparable to receiving stream standards. Please change the analytical method for the metals analyses to either dissolved or total recoverable (or both) as necessary in Table 2. If, however, CAM believes that the analytical method should remain as total metals, please provide the Division with a justification of why total metals analyses are valid and please describe how the analytical results will be used in conjunction with the CDPHE receiving stream standards. CAM Response: Per email correspondence with Joe Dudash on March 11, 2011, it was decided CAM will continue to monitor the parameters currently shown in Table 2. Division Response: Response accepted. 97. In Table 2 — Surface Water, on page 2.05 -57 of Section 2.05.6(3)(b)(iv), CAM lists that chromium (Cr) will be analyzed. CDPHE receiving standards require the analysis of both chromium III (Cr +3 ) and chromium VI (Cr +6 ). Please include both chromium III (Cr +3 ) and chromium VI (Cr + ) in Table 2. CAM Response: Table 2 has been revised, please see page 2.05 -58. Division Response: Table 2 is on page 2.05 -61 and it has not been revised. Please make the appropriate changes to Table 2. 98. Please add total hardness, flow, Iab pH and lab conductivity to the list of surface water sampling parameters in Table 2 on permit text page 2.05 -57 of Section 2.05.6(3)(b)(iv). CAM Response: Table 2 has been revised, please see page 2.05 -58 Division Response: Table 2 on revised permit text page 2.05 -61 was amended to include total hardness and flow. However, Iab ph and lab conductivity were not added to the table. Please explain.