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29. Before Tecfrnicnl Revision No. 36 wns approved, dre permit text, orr page 2.05-ISh, stated <br />that a discharge grub sample would be taken from the mine water discharge pond, <br />analyzed and the resrdts reported in the AHR. On page 2.05-33 of Volrune 1 of the PR-04 <br />submittal, that commitment no longer exists. Please explain why this commihnent wns <br />deleted ar:d submit a revised permit page containing the comrnihrrent, if appropriate. <br />OMLLC gave several reasons why they did not feel that a commitment to sample an SAE <br />for effluent standards was required or, in some cases, feasible. The Division believes that <br />i[ is preferable for an operator [o commit [o this sampling. In some cases, such as at the <br />methane de-gas drill sites, there are discharge points which can be sampled after a <br />precipitation event. Also, it is logical that the design of an SAE does not guarantee <br />compliance with effluent standards. Only direct sampling and analysis can verify [he <br />success of the design. This is comparable to the design and subsequent discharge <br />sampling at a sedimentation pond. The Division requests that OMLLC commit to this <br />sampling a[ SAE's. <br />55. There cere several discrepancies between the list of the hydrologic monitoring site <br />locations found on page 1 of Exfrihit 2.05-7 irr Volume /2 of the PR-04 submittal and drat <br />found on page 2.05-46c of Volrune 1 of dre permit application. Please rectify the trvo lists <br />of site locations and provide revised pages. <br />The Division has no further concerns. OMLLC provided a reasonable justification for [he <br />elimination of hydrologic monitoring at several surface and ground water monitoring <br />stations. The surface water monitoring stations are AG-1, BC-1, BG-l, CG-1, HP-1, P-1, <br />T-I and U-l. The groundwater stations are wells SC-2, WSCDHI2, TC-l and TC-2, as <br />well as springs SP-1 through SP-7, SP-]0 and SP-1 I. <br />A review of the Annual Hydrology Reports shows [ha[ surface water stations AG-l, BC- <br />l, BG-1, CG-1 and HP-1 have not had any flow since the sites were monitored in 1992. <br />Surface water site U-1 did receive 7 cfs of flow during April of 1993 and was recorded as <br />being damp for three consecutive monthly observations, March, April and May, in 1992. <br />Surface water site T-1 has recorded flow most of the year but is located just east of the <br />permit boundary, away from mining. Surface water monitoring site P-I is part of an SAE <br />sediment control structure, so no formal monitoring point designation is needed. <br />However, this does not remove the requirement of the operator to sample the discharge <br />from an SAE. Please see the Division's response to item number 29 above. <br />Information supplied by OMLLC shows [ha[ room and pillar mining ceased five years <br />ago under drainages that are monitored at sites BC-1 and U-l and longwall mining ceased <br />more than a year ago in the drainage area upgradien[ of site HG-1. Longwall mining will <br />be completed under the drainages for sites AG-1, BG-1 and CG-1 in the next year and a <br />half, but those drainages are tninor and show no baseline flow. Only a very small amount <br />of mining occurred under the drainage area that is monitored by T-l <br />4 <br />