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Requirement Regulation Comment <br /> exceedances also occurred in well GP-9 prior to mining in the <br /> area upgradient of this well. Other groundwater quality factors <br /> (e.g.,concentrations of TDS and sulfate)continue to remain <br /> within historical sampling ranges and indicate that coal spoil <br /> leachate has not reached GP-9. The concentration of Boron has <br /> been the highest concentration since 1990. <br /> Flume Gulch alluvium could also be contaminated by coal spoil <br /> leachate. The Coy well is the groundwater point of compliance <br /> for the Flume Gulch alluvium,as explained on page 4-242 of the <br /> permit application. Sampling data from 2020 indicates no <br /> exceedances of the Basic Standards for Ground Water for the <br /> classification of agricultural use at the Coy well. Previously high <br /> concentrations noted in 2019 of Fe and Mn have decreased to <br /> historic ranges. <br /> GF-6 had the highest concentrations of TDS and Manganese <br /> (Mn)to date. The Mn concentration was 0.057 mg/L which <br /> exceeded the Basic Standards for Ground Water of 0.05 mg/L. <br /> J-1 Boron(1.44 mg/L)and total Manganese (0.067 mg/L) <br /> concentrations were the highest on record. There is no standard <br /> for total Manganese and in Table 3 of the Basic Standards for <br /> Ground Water the standard for Boron is 0.75 mg/L.However the <br /> Boron standard is protective of cultivated plants. If crop <br /> watering of specific plants is not reasonably expected the <br /> standard for Boron is 5 mg/L. <br /> P-1 TDS concentrations were the 2nd highest ever recorded with <br /> a gradual increasing trend.What accounts for the increasing <br /> trend? Sulfate(SO4)has been gradually increasing with some of <br /> the highest measurements have been recent. What accounts for <br /> the increasing trend?The 2020 sample results for P-1 are <br /> missing from page B-179,B-240, and B-300,please update and <br /> provide. <br /> P-8 had the highest concentrations of Manganese (Mn)to date. <br /> The Mn concentration was 0.388 mg/L which exceeded the <br /> Basic Standards for Ground Water of 0.05 mg/L <br /> GMP-1 had the highest TDS concentration,3010 mg/L,on <br /> record. The highest concentrations of chlorine (78 mg/L), sulfate <br /> (1460 mg/L)and,manganese (0.248 mg/L)were also recorded <br /> at this location. Only chlorine did not exceed its respective <br /> standard listed in the Basic Standards for Ground Water. <br /> GLEV-3 saw the highest recorded concentrations of the <br /> following analytes;TDS,iron(tr),chlorine,potassium, <br /> magnesium,barium,boron,chromium,fluoride,manganese(t), <br /> nitrate,and selenium. While groundwater flow directions in this <br /> location indicate concentrations are naturally occurring a <br /> continued increasing trends will warrant additional explanation. <br /> Page 4 <br />