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Springs SP-1 through SP-7, SP-l0 and SP-1 l are considered the result of the re- <br />emergence of surface runoff from precipitation events, not from bedrock aquifer flow. <br />Groundwater well sites TC-1 and SC-2 are completed in the Rollins sandstone, but <br />monitoring can be eliminated in the two wells because well TC-2 is also completed in the <br />Rollins. Well TC-2 can be eliminated because the well is completed in the North Fork <br />alluvium that lies to the east of any mining. Well WSCDHI2 is a very deep methane de- <br />gas hole for the Hawk's Nest Mine. Its value as a monitoring well is very limited. Except <br />for a slight indication of water in 1996, it has been dry for many years before and since <br />1996. <br />56. There are several discrepancies benveen the hydrologic monitoring fi~eyteency <br />information found in the monimring freyuency summary on proposed page 2 of Erltibit <br />2.05-7 of Volume 12 of the PR-04 srebmittnl acrd that in the approved monitoring <br />freyuency list found in dre footnotes of permit application page 2.05-46c. Please revise <br />proposed page 2 to reflect the approved monitoring freyuency. <br />OMLLC is requesting a reduction in monitoring frequency for all surface water sites. The <br />reduction in monitoring frequency would include no winter monitoring, November <br />through March, of any of the surface water sites. <br />The Division remains convinced that a complete elimination of winter hydrologic <br />monitoring for all surface water sites is not warranted. Obviously, Ylow in the North Fork <br />of the Gunnison is year round and sites are accessible for sampling. The historical record <br />does show that there has not been any flow at any of the other surface water stations in <br />the winter months for the last decade, except for Hubbard Creek. In the case of Hubbard <br />Creek, [here is no required monitoring from November through March anyway. The <br />Division agrees [hat winter monitoring of all surface water sites. except for [hose sites on <br />[he North Fork of the Gunnison, can be terminated. <br />If you have any questions, please let me know. <br />Attachment <br />cc: Sandy Brown (w/o attachment) <br />c:\ms97\sanbom\pr4memoo <br />m:\coal\jj d\pr4memo4 <br />