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values between these spikes. H -1 is located between the Bowie No. 2 upstream and downstream <br />points on Hubbard Creek; BRL did not report elevated TSS at either location on Hubbard Creek. <br />Again, the Division will look at the data in the next few years to see if there is an identifiable trend <br />and whether or not it is mine related. <br />Surface Water Locations on Bear Creek: <br />5. Chloride at B -1 — The comments made for chloride concentration at H -1 apply to this location, as <br />well. <br />6. Total Suspended Solids at B -1 — OMLLC did not discuss the 2009 -2011 increase in TSS, most likely <br />because the discussion in the 2012 report is limited to the 2012 data. The data indicate that TSS was <br />elevated from 2009 through 2011, and the highest value recorded in April 2011 correlates with the <br />elevated discharge resulting from the 2010/2011 heavy snowpack. The data from the single <br />monitoring event in 2012 show a return to normal values, but data from the next few years should <br />be used to confirm that. Since OMLLC does not sample upstream for TSS analysis, The Division is <br />unable to rule out mining related impacts on the fluctuations in TSS. <br />7. Orthophosphate at B -1 — OMLLC did not discuss the increased orthophosphate concentration that <br />began in 2011. Again, a lack of upstream data makes it difficult to determine whether the increased <br />orthophosphate concentration might be mine related. Does OMLLC have any additional <br />information or an explanation for this increased concentration? <br />Surface Water Locations on Elk Creek: <br />8. Chloride at E -1 and E -2 — The comments made for chloride concentration at H -1 apply to these <br />locations, as well. Additionally, although there is an increase in concentration moving downstream <br />along Elk Creek, the data do show increased chloride both upstream and downstream. <br />9. Nitrate /Nitrite at E -2 — OMLCC does not make mention of or offer an explanation for the increased <br />nitrate /nitrite concentration. This site being the upstream point, it is not likely that this increase is a <br />mine related impact. <br />Surface Water Locations on the North Fork of the Gunnison: <br />10. Chloride at NF -3 — The comments made for chloride concentration at H -1 apply to this location, as <br />well. However, chloride is not elevated at N -1, upstream of the mine, nor is it elevated at the West <br />Elk monitoring locations on the North Fork. The increased concentration moving downstream <br />reflects the increased loads coming out of Bear Creek, EII< Creek, and Hubbard Creek, and is not <br />likely a mine related impact. Future monitoring data will be reviewed to better determine the <br />source of this increase. <br />Should you or the operator have any questions or need additional information, please let me know. <br />