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2014 AHR <br />Sampling Locations <br />The required water monitoring locations for the New Elk Mine are in the PAP, including the text of <br />Section 2.05 and Table 27. The 2014 AHR includes data for all of these sites except: <br />• PRS -la and PRS -4a <br />• PAWla <br />• NM -23. <br />Please explain the lack of data for these sites. If they are temporarily or permanently inactive, please <br />explain this in response to this letter and include a discussion in future AHRs. Also, please consider <br />they should be removed from the monitoring plan in the PAP with a revision. <br />The NPDES data is included by reference in the AHR. Actual data can be found in quarterly Discharge <br />Monitoring Reports. This procedure is in compliance with the rules and the permit. <br />Monitoring Frequency <br />It appears that there is insufficient data in the 2014 AHR to determine when sampling of groundwater (not <br />including alluvial wells) occurred. The only information for these groundwater sites is in the form of an <br />annual summary table, however the monitoring plan requires more than one sample per year for some of <br />these sites (e.g., NE -1-10 should be sampled quarterly). In future AHRs, please provide the original <br />data field notes and lab reports) for all monitoring locations, including locations in the mine workings <br />and bedrock wells. <br />List of Water Quality Parameters <br />Please explain the lack of water quality data for Wells NEW -2, NEW -3, and NEW -4 in 2014. <br />Analysis of Surface Water Data <br />Regarding water quantity, the data do not provide evidence that the hydrologic impacts of mining have <br />been more deleterious than the impacts predicted in the Permit Application Package (PAP). <br />Review of New Elk Mine AHRs <br />Page 3 <br />