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Response to December 5, 2013 2011 AHR Review <br />Item 1 a — Alkalinity values will be added to the 2013 AHR tables and graphs. <br />Item lb. - The P quarter iron (FE) data for NF -3 will be corrected to include the data. <br />Item lc — The flow data comes from USGS stations. The USGS does not have a station on <br />Hawksnest Creek so the HN -1 data comes from the site data obtained at the time the water <br />sample is taken. The H -1 table and NF -1 Table (which also represents NF -3) presents the <br />required data. During winter ice conditions, the USGS qualifies there data as "estimated" data <br />rather than measured discharge. The 2013 AHR will select two years to report. <br />Item Id. The USGS North Fork Station data represents both NF -1 and NF -3. The Division <br />should be aware that the future of the USGS Station may be adversely affected by funding <br />considerations. <br />Item 2a. As we note in the report, the SC -3 well is completed in the B -Seam updip of the <br />mining area. SC -1 well is completed in the Rollins sandstone, up- gradient relative to the B -seam <br />mining footprint. The Division often characterizes a single occurance of the increase in a particular <br />parameter as "a significant increase quantity" of that parameter. We suggest that a one -time spike in a <br />parameter does not meet the threshold of a significant increase or a trend and longer term trends in the <br />data is more important to monitor than isolated spikes in the data. The 2013 report notes an increase in <br />SC -3 sulfate that peaked in 2012 with a decrease observed in 2013. <br />Item 2b. SC -1 exhibits a lowering of the water level and reduction of bicarbonate. Water level has <br />dropped from around 96' (8/2006) to 147' (7/2013) Perhaps regional drought conditions have impacted <br />the water level and the level of bicarbonate. The 2013 AHR will include additional data for review and <br />analysis. Water level in the Rollins Sandstone well continues to drop. <br />Item 3a. Regarding wells BC -1, EC -14 and EC -15, Oxbow does not agree with the <br />Division's assertions. We see little more than variable analytical results, with the small scale of <br />the y axis of the graphs and lab detection levels influencing perceived changes. The 2013 AHR <br />includes additional data for review and possible analysis. <br />Item 3b. Regarding wells BC -1 and EC -14, Oxbow does not agree with the Division's <br />assertions about pH. We see little more than variable analytical results with the small scale of the <br />y axis of the graphs influencing the perception of changes in pH. The 2013 AHR includes additional <br />data for review and analysis. <br />Item 3c. Regarding HCO3 data for BC -1, EC -14 and EC -15 we see just one recent data point <br />showing a decrease. It is certainly premature to draw any conclusions. The 2013 AHR includes additional <br />data for review and potential analysis. <br />• Page 2 <br />