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:f Mr. Kent Gorham, CMLRD June 2, 1992 -page 2 B. Monitoring Frequency After scrutiny of the Division's comments, Trapper concurs that some data were inadvertently omitted as required in our mining reclamation permit. Trapper will address each item as presented in the Divi- sion's review and address the reason data may have been omitted. During 1991, a change in Trapper's monitoring personnel, the proposed TR-54 reduction of monitoring intensity (3/15/92) and final Division approval in mid-June (TR-54) caused confusion with monitoring frequenry for water elevations and some parameters especially for those wells in the East Panel not associated with active mining. For the fast two quarters, sites GPI, GP2, GP7, GP8, GP9 and COY were still on the annual frequency established mid-1987 (TR-32). During the 4th quarter, after TR-54 approval, the water level requirement was inadvertently overlooked by Trapper sampling personnel - footnote 7 (Table 4.8-13a) was messed. Complicating the issue for the Trapper employee responsible [or appropriate sampling was the fvst paragraph on p-247a which states "... quarterly sampling of the far eastern wells is dropped because mining should not affect..." This statement was intended to ensure qualitative parameter sampling was not a requirement; however, Trapper's intent was to wnduct quar- terly water elevation sampling. Trapper regrets this oversight but feels strongly that the data integrity has not been compromised as there still exists consistency of the water level information for the non- artesianwells GP2, GP7, GP8, GP9 and COY. First quarter 1992 water level measurements conform to previous sampling consistency. There should be no omissions of water level data in the future, unless adequately documented. la) Sites GP-1, GP-2, GP-7, GP-8, GP-9 and COY: There is one water elevation reading missing for these six sites as addressed above. The fourth quarter readings were inadvertently overlooked and no data is available. lb) Sites GC-1, GC-2 and GC-3: The first quarter was still annual sampling only and 4th quarter water level measurements were not taken. lc) Sites GA-1, GA-2: These sites were proposed for biannual (BA) sampling and an annual TDS requirement First quarter levels (FQL) were not taken. Site GB-1: The FQL was taken 3/26 but not recorded on the field sheet nor separate notes. No data is available. Sites GD-2, GF-1, GF-2, GF-3, GF~i, GP-3, GP-0, GPI: Proposed for reduction to BA sampling. Levels were erroneously not taken. Site GF-11: All level measurements were taken. First quarter reading (3/28) of 6750.8 was not entered into data tables. Site P-5: All level measurements were taken. Second quarter reading (6/28) of 6363.7 was not entered into data tables. Site P-8: All level measurements were taken. Third quarter reading (9/13) of 6474.3 wasn't trans- ferred from field notes to Hydro-Engineering summary table and subsequently not reported. ld) Site GA-2: Water levels and subsequent water volumes have made it almost impossible to obtain a representative sample since 1990. The well depth is 177 feet and water (mud) levels were less than 2 feet above the bottom all year. Pumping in the third quarter (annual sampling) was impossible as even air lifting couldn't obtain a representative sample. le) Site GF-6: Proposed for biannual sampling in AHR since there is no ash upgradient Final CMLRD approval required quarterly analysis of List C and no annual TDS requirement (TR-44). The first two quarters missed list C parameters except for a water level (7/15). The annual TDS, list B, list C fourth quarter were taken and reported.