Laserfiche WebLink
have been used pre-mining or will be used post-mining and what <br />the effect of mining will be on the springs (same as item <br />number 2 above). <br />4. OSM believed that springs should be sampled for more than the <br />current list of parameters. The required water monitoring <br />parameters for springs is similar to the NPDES discharge <br />parameters. OSM would like to see the list include the full <br />suite parameters, which was referred to as SMCRA parameters. <br />Also, it was desired that natural springs be included in the <br />water monitoring plan. <br />The approved water monitoring plan for springs is located on <br />page 4-241c of the permit application. As footnote no. 1 on <br />that page states, the plan only concerns spoil springs whose <br />flow exceeds 5 gpm, and only those parameters shown in list A- <br />1. Because these spoil springs have a possibility of providing <br />water and habitat for wildlife, the Division agrees that <br />additional water quality monitoring parameters should be <br />sampled on spoil springs. Also, since there is a possibility <br />that the pre-mining natural springs could be affected by <br />mining, the Division believes that these springs should also <br />be sampled for the same chemical parameters that the spoil <br />springs will be sampled for. <br />The Division requests that Trapper revise its spring water <br />quality monitoring program, to include natural springs and <br />spoil springs, and to reference list A-3 for the parameters <br />required to be sampled. The Division proposes that this <br />sampling be done once a year, by May 15 of each year. <br />5. OSM would Like to see a detailed description of how the <br />operator samples for water monitoring. This description would <br />include what procedures are being used to obtain the water <br />samples and what measures are being used to ensure holding <br />time and chain of custody. <br />The Division commented that Rule 2.03.3(4) already requires <br />the operator to follow a standardized methodology for water <br />sampling. However, the Division sees the advantage of having <br />the sampling procedures spelled out in the permit. Trapper has <br />agreed to include water sampling procedures in the permit <br />application. <br />6. In the Annual Hydrologic Report (AHR), OSM would like to see <br />charts and graphs that depict all of the data, baseline up to <br />the present monitoring, not just the last few years. <br />The Division agrees that this suggestion would result in a <br />better AHR, since a reviewer would not have to go through <br />several previous AHR's in order to assess the water quality <br />effects over the years. The Division requests that Trapper <br />4 <br />