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<br />downstream of the mine site. The proposed Hydrologic Monitoring Plan <br />should be modified to include surface water quality and quantity sampling <br />at these two locations. Water quality upstream on Foidel Creek <br />preferably should be monitored at USGS Gaging Station 09243900, and a <br />downstream gaging station should be installed on Middle Creek near CYCC <br />site 29. Monitoring frequency for these locations should be synchronized <br />with the other monitor sites on Foidel and Middle Creeks in accordance <br />with the schedule in Table C (Exhibit 15). <br />BESPONSS: <br />CYCC maintains that the surface water data collection program <br />conducted at Mine No. 3 is adequate to detect, within acceptable <br />degrees of confidence, all effects of mining on streams in and <br />adjacent to the permit area. As shown in Table 27, USGS Stream <br />Monitoring Data, eight years of data on surface water quantity and <br />quality have been collected at Station 09243700 on Middle Creek and <br />Station 09243900 on Foidel Creek, upstream from Mine No. 3. These <br />data are additive to the five years o£ data collected by CYCC. <br />One of the most common and widely accepted practices of <br />hydrologic analysis is the accounting method. This method is used <br />for example, by the U.S. Geological Survey in the Salt Accounting <br />Model, which has been utilized and accepted by the Mined Land <br />Reclamation Division. The accounting method is a mass-balance <br />procedure which in its moat simple £orm, adds up all contributions <br />and subtracts all depletions to the stream system. Given the proper <br />input, the method is equally applicable on a local or regional <br />-10- <br />