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4 ~ • • <br />DIVISION ADEQDACY RESPONSE 12/15/87 <br />4.8.5.1 Surface Water Monitoring <br />The results of each year's surface water monitoring, excluding NPDES <br />samples, should be included in the Annual Hydrologic Report. This report <br />now only contains ground water information. As Middle Pyeatt is to be dis- <br />turbed, it should be included as a site for semi-annual analysis of List <br />A-1. East Buzzard and West Buzzard are also to be redisturbed and should <br />be included in the semi-annual analysis of List A-1. <br />List A-1 must be revised to include bicarbonate (HC03), calcium (Ca), <br />magnesium (Mg), sodium (Na), and SAR. Bicarbonate is a major constituent <br />of water and can depict changes in water chemistry. The latter parameters <br />are required as high SAR levels have been detected in the ground water <br />wells and backfilled spoils wells. The (or) after TDS should be removed. <br />TDS and conductivitiy must be analyzed on a semi-annual basis to allow the <br />determination of the relationship betweenthe two parameters. This will <br />allow interpretation of the conductivity submitted for the more frequent <br />NPDES sampling. <br />TRAPPER'S RESPONSE: <br />Trapper Mining agrees to provide the Division surface water quality data as <br />part of the annual hydrologic report. Page 4-241a of PR-2 permit revision has <br />been so revised. <br />In our February 1987 submittal of PR-2, Middle Pyeatt, East and West Buzzard <br />gulches, we proposed to be sampled as requested by the Division. Tables <br />4.8-lla and 4.8-12a have been revised to more clearly illustrate the sample <br />frequency at each site and the parameters to be evaluated. The tables also <br />reflect an effort to make the tables compatible with our NPDES permit require- <br />ments. <br />Effluent from site NPDES 007 now flows into pond number 10 in Johnson Gulch <br />(MR56). The site, therefore, is in the process of being removed from the <br />NPDES system. <br />Finally, Table 4.8-12a has been revised to include the requested parameters to <br />be added. Both TDS and Conductivity will be measured a[ least semi-annually <br />at all discharging NPDES points until a mathematical relationship acceptable <br />to the Division is established. <br />