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NOV. Apparently, data sheets detailing the results of a laboratory sample taken in May <br />of 1998 were located. Considering this additional information, CYCC successfully <br />completed three of the four required quarterly visits for water level and field parameters <br />and took two full suite laboratory samples, one in the middle of the second quarter <br />(May) and one in the middle of the third quarter (August). Anew page was also <br />submitted for the AHR text. The language stating that "the fall 1997 water quality <br />sampling of these wells was inadvertently missed" was replaced with the text "All <br />sampling requirements were completed at these wells during 1998." <br />Staff Response <br />It is not clear to the staff which sample (May 1998 or August 1998) the operator is <br />maintaining meets the fall 1997 sampling requirement. Additionally, no water level or <br />field data was submitted for the 4'" quarter of 1997. Semi-annual water quality <br />laboratory sampling is commonly chosen as a way to determine seasonal variation <br />while imposing a minimum sampling burden on the operator. Seasonal in northwest <br />Colorado requires a sample after snowmelt and infiltration (spring) as well as sampling <br />following the growing season prior to hard ground freeze and winter conditions (fall). <br />This important information is used by the Division for determinations of impacts prior to, <br />and during, bond release reviews. Without a continuous record of regular water quality <br />information, determination of ground water impacts can be difficult, if not impossible. <br />The staff believes the NOV is appropriate. <br />If you have any questions, let me know. <br />Attach: Request to Vacate Letter <br />Original AHR pages <br />Replaced AHR pages <br />Lab Sample sheets <br />Chain of Custody Forms <br />CC: Dan Hernandez <br />David Berry <br />