ENFORCE35139

• Permit No: C1980001
• IBM Index Class Name: Enforcement
• Doc Date: 7/9/1992
• Doc Name: EDNA MINE PERMIT RENEWAL ADEQUACY CONCERNS C-80-001
• From: MLRD
• To: PITTSBURG & MIDWAY MINING CO
• Violation No.: CV1994016
• Media Type: D
• Archive: No

,,/ ~
4.6-142a contai
derive those sa
whether the TDS
derived from th
equation on pag
reported data ha
ns a second equation which was apparently used to
me numbers after November, 1990. It is not clear
numbers in Edna's AHR are analytical results, are
e equation on page 2.5-95 or are derived from the
e 4.6-142a. Furthermore, it is not clear whether
s been corrected to 25 degrees Celsius or not.
In addition, the conductivity measurements in the AHR have no
consistent relationship to the associated TDS numbers. At times,
TDS values exceed conductivity values while at other times, there
is an inverse relationship. Use of the equation on page 4.6-142a
results in TDS values which are always in excess of conductivity
values. Based on available literature, conductivity values should
always exceed TDS values. In light of these observations, the
conductivity and TDS data in Edna's hydrologic monitoring program
may be of questionable value.
P & M should,
a. clarify whether conductivity readings ar.e corrected
for temperature,
b. clarify how TDS numbers for both surface and
alluvial well water samples were derived and,
c. explain how TDS values may exceed conductivity
values or remove the equation on page 4.6-142a of the
permit and correct any calculated TDS values which have
been derived using that equation and.
3. The hydrologic monitoring program at the mine site has
experienced problems in recent years related to equipment failure,
flooding and beaver activity. As a result, conductivity
measurements of surface and ground water samples have been erratic
and of questionable value and surface flow measurements have only
been consistently collected at one site on Trout Creek. In order
to meet the requirements of Rule 2.05.6(3j(b)(iv) and to ensure
that adequate data is collected to make the required demonstrations
regarding protection of the hydrologic balance, the Division
requires that P & M
a. incorporate at least one flow monitoring station on
Trout Creek downstream from station TR-a into the
hydrologic monitoring plan,
b. add a laboratory analysis for TDS to the list of
parameters to be evaluated for surface and ground water