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1993, 1994 AHR Responses (#2) <br />February 6, 1997 <br />Page 3 <br />The request to submit laboratory reports and chain-of-custody forms will be addressed in <br />the responses to the Division's request for a revision to improve the hydrologic <br />monitoring program (letter also dated December 9, 1996). <br />12. The initial footnote No. 1 has been modified on pages 2, 3, and 5 of 6, and all of Table H- <br />1 has been revised for your incorporation into the AHR. <br />17. The baseline minimum and maximum values have been relabeled on Table F-1 for the <br />Jumbo Spring No. 6 Pond. <br />19. TSS was not collected for GP-1 during baseline sampling. TSS is not a standazd measure <br />of ground water quality and has subsequently been removed from the ground water <br />monitoring program. As a consequence, MCC has not modified the Table. <br />22. The baseline data for the North Fork of the Gunnison sites were collected from 1977 <br />through 1980, seventeen to twenty years ago. The Division's suggestion is valid that <br />reseazch (and verification) into the baseline iron and manganese concentrations should <br />examine the original source (i.e., the original laboratory sheets). However, MCC also has <br />to assume that the data from the laboratory data sheets has been correctly transferred to <br />the tables in the AHR and that if there were any errors, the Division would have noted the <br />errors at the time the data was submitted. MCC observes that many of the original data <br />sheets provided by laboratories did not specify whether the metal was analyzed in its <br />dissolved or total forms. The earlier data reflects such small concentrations that most <br />likely the samples were filtered and the dissolved form reported. In addition, the 6.96 mg/l <br />of iron was measured during spring runoff during a year in which there was an above <br />normal snowpack. Iron during this time was measured in its total form; and therefore, the <br />higher concentration is likely due to the high amount of sediment in the river. Impacts are <br />more appropriately observed during low flow conditions. MCC now collects iron in its <br />dissolved form as well as total iron (per TR#71). <br />As MCC was again reviewing the laboratory sheets and the AHR tables, an error was noted on <br />Table E-1 and a corrected table is provided. <br />MCC intends continued compliance with our monitoring program and the Regulations. The <br />missed parameters were not intentional, but human error. Human error is also the reason for the <br />errors in transcribing the data from the laboratory data sheets to the AHR tables, and MCC <br />apologizes for any confusion these errors may have caused. MCC is currently working on a <br />better tracking system to verify that all required samples and analyses are completed on the <br />numerous resources monitored. <br />