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<br />J. J. Dudash - 6 - January 17 2001 <br />soon after its installation, preventing proper monitoring during the fall of its <br />installation. The well is now functional and will produce results for the 2000 AHR. <br />The monitoring point known as AW-2 is an Alluvial Well located near the entrance <br />to the mine along old Highway 133. This well does not produce sufficient water <br />for a full suite analysis or even field parameters. It is possible to measure water <br />depth, but not have the ability to draw water. <br />15. In the hydrologic monitoring point tables presented in the PR-04 submittal, for <br />surface water and ground water sampling sites, there are several required <br />chemical parameters that are missing from the full suite baseline data. Please <br />explain these omissions. <br />BRL -The chemical parameters noted as "missing" are results where the <br />chemical was found below the Method Determination Limit (MDL) of the <br />laboratory. These missing results are now annotated as "<MDL". If the laboratory <br />did not analyze for a chemical parameter, it is now left blank. New Monitoring <br />Point Tables are included with this response. <br />16. There are quite a few hydrologic monitoring point tables in the PR-04 submittal <br />that do not have field and full suite baseline data listed, although the footnote on <br />each table page states that there is baseline data. Please update the monitoring <br />point tables to show the baseline data. <br />BRL -Sites with blank baseline data fields have footnotes explaining the absence. <br />In several instances, no baseline data is available for points that did not exhibit <br />flows during the baseline evaluation period. For instance, C-Gulch-Lo and B- <br />Gulch-Lo exhibited no flows before mining began and therefore no field or full <br />suite analysis was available, but baseline information was required before mining <br />began. The operator feels that the absence of flow, and therefore the absence of <br />chemical parameters does reflect the baseline of the premining condition of these <br />points. <br />17. There are many sites in the hydrologic monitoring tables that were submitted in <br />PR-04 that have a footnote that states that the baseline hydrology information is <br />not considered complete yet. The Division understands that it may take a while to <br />gather the baseline hydrology information, especially since a lot of the springs <br />have been dry in 1999. However, the baseline hydrology information will be <br />needed before any mining occurs that may affect that particular surface water or <br />ground water resource. The baseline data must include the required field and full <br />suite parameters. <br />The operator will continue to collect data on all points submitted with PR-04 and <br />previously approved by the Division. The 2000 monitoring season will have <br />provided over 3 years of experience on all of the points except the newly installed <br />monitoring wells and S2-9 and S2-10 springs. The 2000 AHR will establish <br />baseline values for all points submitted with PR-04. <br />