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Mr. David Bevy November 24, 1993 Page 3 Six of the eight ground~rater monitoring wells >n the inm~ediate vicinity of the Fast mine facilities should be dropped from the monitoring network. Four have been dry since they were installed in 1982, one experienarl a casing failure at depth in 1988 aryl has been dry ever since, and one is located >r the middle of the main diversion channel above the Fast mine and contains water only during times the rharu~el is actively transporting water. 'This well is was ar~*-Pntly not sealed adequately at the surface during installation. 'iWo wells should continue to be monitored on a quarterly basis. Four of fourteen shallow wlluvium monitoring wells should be temporarily dropped frwn the monitoring network as they are located >n and adjacent to areas over the Fast mine which ceased activity in mid 1986 due to a mine fire. No impacts have been detected by the monitoring that has been oorducted in these areas since 1986 and no new activity has taken place in the Fast mine. Zhe remaining ten shallow wlluvium monitoring wells should continue to be monitored on a quarterly basis. Monitoring of deep groturhrater wells needs to be reevaluated. Monitoring of two wells is c~urently required. Water quality samples cannot currently be obtained from either well and have not been obtainable since 1987. Water levels can currently be obtained frcan only one well (DH-70) located over the Fast mine. OOVCC believes that several surface water monitoring stations can be el;m;nated from the monitoring program as well. Of the 13 surface water monitoring stations requiring monitoring during 1992, cOVCC believes 10 should be permanently dropped frmn the program, 1 should be temporarily discontinued until such time as mining activities in the Fast mine are renewed, and 2 should continue to be monitored on a regular basis. Priorities associated with various aspects of the mining permit and other areas of regulatory corq?liance have prevented OOVCC fran formally approaching the Division with a request to revise the hydrology monitoring program to el;m~*+ate those data collection efforts which are of little or no value in determining the presence, degree, and/or extent of mine impacts to local hydrologic features. cDVOC has in the past held informal discussions with the Division regarT3ing the hydrology monitoring network and believes the Division is in general agreement with the concept of revisit the existing network to more effectively address mi ' operations that are currently underway at Orrharrl Valley and associated hydrologic features which might reasonably be affected. ~VOC asks the Division to wnsider that no significant hydrology impacts have been evidenced to date at Orchazd Valley. Several years of data are available for specific features and no clear impacts are doclmiented. In many cases, m• activities which could potentially affect hydrology features were discontinued in 1986, when the Orchard Valley Fast mine was closed.