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<br /> <br />Mr. William Agnew - 2 - June 7, 1990 <br />Section 2.9 - <br />This section proposes certain reductions in hydrology monitoring <br />requirements. Specific comments regarding the request follow: <br />/Vanadium - The request to eliminate vanadium from the list A-1 is <br />/ accepted. <br />Total Dissolved Solids (TDS) - <br />,~ 1. Our records show confl icting information regarding the <br />requirement to monitor TDS at surface sites. For example, <br />Permit Page 4-241b (revision a e: anuary 20, 1988) seems to <br />indicate that your current proposal has already been <br />approved. However, Permit Page 4-241d (revision date: April <br />16, 1989), footnote number 1, implies that the operator must <br />provide an analysis before TDS can be eliminated. It is also <br />important to note that NPDES requirements dictate that <br />salinity is measured using the TDS analysis. <br />Please clarify this possible discrepancy. If a demonstration <br />has already been provided to verify an acceptable correlation <br />between TDS and conductivity at the Trapper surface sites, <br />then your request can be approved. If, however, no such <br />demonstration has been provided, we must require that that <br />operator provide this information. <br />~/ 2. The requirements regarding TDS monitoring at groundwater <br />sites were modified somewhat with our approval of 7R44: <br />Please provide a demonstration which certifies that TDS and <br />conductivity are sufficiently correlated at the Trapper <br />groundwater sites to allow the currently requested monitoring <br />reductions. <br />Please also provide revised pages 4-243 and 4-244 to reflect <br />the changes approved in the Division letter of May 30, 1989 <br />(TR44). <br />Total Concentration - This reduction request is accepted, <br />/ Ash Wells - <br />It appears that this request applies only to Wells GD-3, GF-7, and GF-11 <br />~/(Permit Pages 4-243 and 4-243). Please advise us if this is not correct. <br />Well GD-3 - It appears that mining will remove this well. Will it <br />be replaced when backfilling occurs? Please explain. <br />We can accept the reduction request for this well if <br />ash disposal does not occur in D Pit. Has ash disposal <br />occurred in D Pit? Do you anticipate that ash disposal <br />will occur at D Pit? If ash disposal will occur at <br />this pit, provide a commitment which verifies that the <br />D list parameters will be analyzed. <br />