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taken during irrigation season only (June-Sept). Table A language stating it was <br />removed during TR-35 review. This is an example of current text/table inconsistency. <br />The text commits to rating the stream flow at sites where the flow is measured with a <br />cable and plumb bob on an outside stream gauge. This "rating" or gauging of the <br />stream is required to be done "late spring or early summer and then again in the fall" <br />of each year. <br />Effluent monitoring is discussed in the text and generally defers monitoring <br />requirements to whatever is identified in the NPDES permit. This is appropriate and <br />prevents.--- 7 <br />Spoil spring monitoring is also discussed in this section. Spoil springs specific to <br />Twentymile are not significant. Monitoring appears to have been done in accordance <br />with the approved plan. <br />Mine Discharge Monitoring <br />The text identifies two mine water discharge points, site 109 and site 115. The text <br />states "At site 109, the mine discharge is sampled quarterly for field parameters and <br />water quality, and weekly for flow and conductivity." Looking back at past AHR's <br />(since at least 1992), I cannot find where site 109 has ever been monitored weekly <br />for flow and conductivity. Table A indicates quarterly'bvatertevel (should read flow) <br />and field parameters" and quarterly `yvater quality sampling". This is another <br />example of inconsistency between Exhibit 14 text and Table A. <br />Site 115 is discussed and again refers the sampling schedule to the NPDES permit <br />0042161. <br />Text discusses the monitoring required if sites 115 and/or site 109 are discharging <br />identifying those extra sites and the increased frequency of monitoring during <br />discharge. The text seems to agree with the plan as stated in Table A with one <br />exception. The site downstream of site 115, that is discussed in the text and shown <br />on Map 13A, is not included in Table A. It is labeled on the map as "downstream". <br />As far as I can tell, we did not get any data for this site in the 2000 AHR. This seems <br />like a significant miss. This location allows the Division some verification that mixed <br />Fish Creek water and mine discharge is not exceeding material damage standards. I <br />believe the site was jointly visited by TCC and DMG personnel in the field. <br />Text discusses the collection of data specific to the mine water discharge plan and <br />the submission of this data to the Division, from the first quarter of 2000 through the <br />1 ~` quarter of 2001, no later than 45 days after the end of the respective quarter. <br />Apparently, this data was not submitted for any of the quarters. The requirement was <br />included by the Division to allow a chance to analyze and discuss monitoring results <br />and head off any problems with data collection or identify misunderstandings in the <br />plan so that they could be corrected quickly. Obviously, the Division and TCC were <br />not afforded the opportunity to do this. <br />• Page 2 <br />