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December 10, 2013 <br />To: Brock Bowles <br />From: Susan Burgmaier <br />Re: North Thompson Creel Mine (Permit No. C- 1981 -025) <br />2012 Annual Hydrology Report <br />Adequacy Review <br />Per your request, I have reviewed the North Thompson Creek 2012 AHR. I have the <br />following comments: <br />1. Water monitoring frequency requirements: <br />The currently approved Hydrologic Monitoring Plan is presented on page 3 -86 of the <br />approved permit application package. There is no requirement to obtain flow data <br />on North Thompson Creek, nor is there a requirement for ground water monitoring. <br />The approved monitoring plan requires water quality samples on North Thompson <br />Creek in May and September for the following parameters: Total Dissolved Solids, <br />pH, Calcium, Iron, Manganese, Sulfate, Copper, Total Suspended Solids, <br />Bicarbonate, Chloride, Magnesium, Sodium, and Zinc. The 2012 North Thompson <br />Creek samples were not analyzed for Calcium, Sulfate, Bicarbonate, Chloride, <br />Magnesium, or Sodium. Please explain why full suite samples were not <br />performed and /or documented in the 2012 AHR, as required by the approved <br />permit application package and Rules 4.05.13(2), (3), and (4). <br />2. CDPS monitoring: <br />Minrec, Inc. reports no discharge at Outfall 001, since there was no discharge <br />directly to North Thompson Creek. It is our understanding that any discharge <br />through the Outfall 001 flume would constitute a discharge at this point, regardless <br />of where the flow is directed after crossing the Outfall 001 discharge point. <br />Accordingly, the Division believes that Minrec, Inc. should be recording and <br />analyzing discharges from Outfall 001 in accordance with the approved CDPS <br />permit. <br />3. Surface water quality: <br />The water quality data provided for North Thompson Creek indicates little change in <br />water quality at the downstream point, below Outfall 001, when compared to the <br />upstream data. Monitoring data does not indicate that there is any mine related <br />degradation in water quality on North Thompson Creek. <br />4. Monitoring results to date are generally in line with the predicted impacts to the <br />hydrologic balance summarized in the report and detailed in the approved permit <br />application package. <br />Should you or the operator have any questions, please let me know. <br />