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The Division believes that the number of exceedences of <br />holding time is minute in comparison to the total sampling <br />that Trapper performs throughout the year, that there is no <br />pattern of negligence, and that the exceeded holding times <br />were very short in duration, probably not affecting the <br />testing results to any meaningful degree. The Division does <br />request that Trapper look into getting a contract with a <br />laboratory that is closer to Craig so that this issue won't <br />come up at all. Trapper must adhere to established sampling <br />and analysis protocol for all future sampling. <br />11. The flume below the Coyote pond needed leveling. The Division <br />stated to OSM personnel at the time that this issue had <br />already been brought up with Trapper during an earlier <br />inspection, as a normal maintenance item. Since the special <br />focus inspection, Trapper has reported that the Coyote flume <br />has been leveled. <br />OSM thought the flume in Flume Gulch needed leveling also. The <br />flume may have been off a little. Trapper must ensure that all <br />flumes are level. <br />12. OSM was concerned that the flumes were too large to sample <br />flow when spring and seep flow were being sampled. This would <br />only apply to the Coyote spring and the East Pyeatt spring, <br />since the other springs have their flow measured by the bucket <br />and stopwatch method. The Coyote and East Pyeatt springs are <br />not spoil springs. <br />The lowest reading on the flume's staff gauge equates to a <br />flow of 4.48 gpm. The trigger flow, as required in Trapper's <br />PAP, for initiating water quality monitoring of springs and <br />seeps is five gpm. OSM suggested that Trapper use a portable <br />weir that would provide more accurate readings at low flow. <br />The Division believes that this is a reasonable request. <br />Trapper has reported to the Division that a portable weir has <br />been ordered and is now on site. <br />OSM was also concerned that Trapper personnel may not be using <br />the flumes appropriately. OSM pointed to literature on flumes <br />that stated that the minimum flow that should be read from a <br />12 inch throat parshall flume was .il cfs, or 49.4 gpm. <br />The Division has been investigating this matter. Trapper <br />provided two sets of information to the Division that they had <br />received from the flume manufacturer. The first set of <br />information was the manufacturer's literature and design <br />specifications that had come with the flume. The free-flow <br />discharge table in that literature shows that the lowest <br />discharge value appearing in the table, for a one foot wide <br />throat, is .35 cfs, or 157 gpm. This flow would occur at a <br />6 <br />