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T. Bird, GCC Energy, LLC <br />AHR Review — 2011, 2012 & 2013 <br />21- Apr -2014 <br />Page 2 of 3 <br />4. Fluctuations in the depth to water appear to have increased in magnitude between 1998 <br />and 2008, but have reduced in recent years. <br />Please provide a discussion of the rater level in upcoming AHRs. <br />Ki gg 1 <br />5. Page 3 of Section 2.05.6 in the King II permit Iists twelve parameters that will be <br />monitored. Data for each of the twelve parameters was reported. In addition to the 12 <br />requisite analytes, the AHR also includes data for Hardness, Alkalinity, Carbonate, and <br />Hydroxide. <br />6. The permit text indicates only that a "Down- Gradient" baseline well will be monitored; <br />however, data has also been collected on a quarterly basis from an up- gradient well since <br />2005. Please revise the permit text to reflect both of the King II groundwater <br />monitoring sites (Map King II -004 illustrates the locations of the up- gradient and down - <br />gradient wells). <br />7. The AHRs do not indicate the laboratory method used for determination of Calcium, <br />Iron, Magnesium, Manganese, and Sodium. <br />With future AHRs, please indicate whether the results represent Dissolved or Total <br />concentrations. <br />Surface Water Monitoring <br />1. King I sampling occurs only from the CDPS discharge points (the east and west ponds). <br />Sampling parameters are listed in Section 2.04.7 p. 1, and include Conductivity in <br />addition to those parameters listed in the WQCD Discharge Permit for the mine. No <br />discharge occurred during the three reporting years under review. <br />2. For King II, any discharges from the sediment pond will be monitored in accordance with <br />the Discharge Permit. (No discharge occurred during the three reporting years under <br />review.) The AHR for King II has generally reported quarterly data for the Hay Gulch <br />Irrigation Ditch.. The list of parameters is identical to that used for the ground water <br />wells. <br />Please submit an application to revise 2.05.6p. 3 of the permit to indicate that the Hay <br />Gulch .Irrigation Ditch is monitored on a quarterly basis, and that the list of ground <br />water parameters applies. <br />Rule 4.05.13(4) - Monitoring Report Requirements <br />(b) Ground water and surface water data collection shall be based upon a water year <br />(October l through September 30), unless otherwise approved by the Division. <br />Data for the King Coal AHRs has typically covered one year's time, running from July 1 <br />through June 30. The Division was unable to find language in either the King I or the <br />King II DRMS permits stating what dates the monitoring year will span. <br />