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Jason Musick <br />Page 2 of 2 <br />February 27, 2015 <br />4. Data from DH -49 (Figure 141) shows several constituents (chloride, bicarbonate, conductivity, <br />TDS, Sulfate, and Sodium) much higher than baseline conditions. BRL does not mention this <br />trend in their summary of groundwater monitoring. Please provide a discussion of the <br />monitoring results of DH -49 to include a possible explanation of this trend of overall water <br />quality degradation, and whether monitoring results align with the predicted impacts to the <br />hydrologic balance. <br />5. The summary on page 4 of the report states that alluvial well monitoring during the 2013 <br />sampling season provides results consistent with baseline information provided in the permit <br />application, showing no adverse impact to groundwater excepting wells AW -16 and AW -17. <br />Reviewing the data, it would appear that there are several instances where monitoring data <br />indicates degradation over baseline values at wells AW -1, AW -3, AW -5, AW -6, AW -7, AW -11, <br />AW -12, and AW -14. While this degradation is consistent with the predictions of impacts to the <br />hydrologic balance in the approved permit application, the sampling data does show a <br />departure from baseline that should be illustrated as such. Please revise the discussion of <br />alluvial well monitoring to include a comparison of 2013 monitoring results to baseline <br />conditions. <br />6. Page 2.05 -127 of the approved permit application package states that the small area <br />exemptions shown on Map 20 will be monitored quarterly, and that BRL will use its best efforts <br />to obtain samples. To date, starting with the 1997 AHR, no samples have been collected at any <br />of the small area exemption sites. Please provide information on what efforts BRL has made to <br />sample these sites, including a discussion of how BRL determines when samples should be <br />obtained. <br />7. General comments: <br />a. Data is presented in tabular form for all monitoring points, and in graphic form for several <br />of the monitoring points. In future reports it would be helpful if the data were also <br />presented graphically for all monitoring points. <br />b. It would also be beneficial if BRL would plot the upstream and downstream data for each <br />surface water site on one graph, to better illustrate the downstream trends. <br />c. Inclusion of baseline data for the all of the ponds enables the reviewer to easily compare <br />current conditions with baseline. Some of the ponds include baseline data, but several do <br />not. (Figures 174 -181 do not). Please include baseline data for all ponds in future reports. <br />d. It would be helpful if BRL would include, in the graphical information for monitoring sites, a <br />point along the sample date axis indicating the changeover from baseline to operational <br />data. <br />This concludes my review comments. Should you or the operator have any questions, please let <br />me know. <br />