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OMLLC replied that the current hydrology sampling parameter list was previously <br />approved in TR-29 on July 15, 1997 and that chemical parameters were dropped due to <br />those parameters being unchanged over an extended time or being below the detection <br />limit. However, upon further review, OMLLC is proposing to add alkalinity [o the <br />surface water and ground water sampling, add sodium, sulfate, dissolved iron and total <br />iron to the surface water sampling and remove mercury and selenium from the ground <br />water sampling. Table 2.04.7-T1 was revised in the November 2001 submittal to reflect <br />these changes. <br />Concerning the pazameter list that currently is in the permit application, the Division's <br />records show that page 2.04-39a, which contains the parameter list, was not revised in <br />TR-29. This is shown on the list of revised pages that was attached to the TR-29 approval <br />form. The Division's records show that page 2.04-39a from TR-20 was mistakenly <br />changed in TR-35 and duplicated in the PR-04 submittal. TR-35 was concerned with an <br />update to the PHC.for mine water discharge, not for a revision to the standard hydrologic <br />monitoring program. The deletions were not a part of any detailed analysis of the data by <br />the Division. Presumably, the mistake was not caught in TR-35 because there was an <br />extremely short time frame in which the Division could review that technical revision. <br />Concerning any reduction in the chemical parameter list, the Division does not agree with <br />OMLLC in this proposal. The Division has a regulatory requirement to ensure that <br />mining operations monitor Colorado receiving stream standards. Also, because [he new <br />' Elk Creek Mine will be opening up soon, one can not draw conclusions a[ the Elk Creek <br />Mine from what was found at the Sanborn Creek Mine. A new mining area may mean <br />that new chemical constituents will be present. Therefore, the Division is requesting that <br />• .the chemical parameters list found on page 2.04-41 for PR-04 reflect the chemical <br />;.. parameters list that exists on page 2.04-39a that had been approved in TR-2Q, with one <br />addition. That addition is hardness since hardness is needed to calculate the table value <br />standard for the receiving stream standard. Attached is a copy of the page 2.04-39a <br />parameter list from TR-20. Please submit a revised page 2.04-41. <br />10. : On PR-04 proposed phge 2.04-51, in Table 2.04-7-T4, and on Map 2.04-M6, no mention <br />Is ntnde of the Oliver Stennt Electric Puittp water right It nppears thnt this page wns <br />revised in Teclutical Revision No. 35 and the reference to this water right was removed <br />front dte table. Please explain why dtis venter right is no longer listed in the table. <br />The operator is correct in responding.that Map 2.04-M6, sheets 1 of 2 and 2 of 2, had <br />already been submitted. The Division received the two map sheets on August 21, 2001. <br />However, the two map sheets do not have signed engineer's certifications. Please submit <br />Map 2.04-M6, sheets 1 of 2 and 2 of 2, with the proper engineer's certifications. <br />25. There are no engineer's certific•cttions on tJte design drawings 2.05-MSC, "Sedimentntion <br />Pond C", 2.05-MSE, "East Ynrd Sedinrentution Pand ", 2.05-MSG, "Upper Hubbard <br /> <br />