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Section IV. -Decision to Require Revisions or Additional Information Rule 2.05.6(2) -Protection of Hydroloeic Balance The following comments are based on the review of the 1999 Annual Hydrology Repots. The hydrology monitoring plan in Section 4.6.8 of the permit does not discuss monitoring location TCS-l and it could not be located on Exhibit 4.6-26. Please include this location in the discussion, on the Table 4.6-54 and on Exhibit 4.6-26. 2. On page 4.6-148 of the permit P&M says that the monitoring frequency may be reduced after 3 years if the quality does not differ more than ± l0%. Data for TCS-1 has been collected for three years and it is presented in Appendix F of the 1998 AHR Is P&M planning to reduce the monitoring frequency for this site? 3. The springs and seeps were not monitored for the full suite of parameters identified in Table 4.6-54. Specifically, temperature, pH, specific conductance, and TDS are missing. (TSS not required) Please include all parameters in the 1999 AHR. 4. No water level or water quality data for the Moffat spoils well, M892S was presented. The permit on p. 4.6-146 says the monitoring will be consistent with monitoring performed on the West Ridge spoil well , WR-l. Please submit the data for 1998, if available, and be sure to include the data in the 1999 AHR. 5. No data for M892L was presented. Please submit the data for 1998, if available, and be sure to include the data in the 1999 AHR. 6. Given the use of data from NPDES discharge points in the calculations of salt-loading in Appendix 2.5-A of the permit, the NPDES discharge data should also be included in the AHR, a practice which hasn't been done in the past. Please summarize the discharge data in the 1999 AHR. 7. Well TR 1.5, upgradient of the mine, has shown unexpectedly high TDS levels. It is interesting to note that the concentrations have remained relatively steady, maybe diminishing slightly. DMG agrees with P&M's discussion that the cause for the increased salinity is unknown, but certainly that high-salt groundwater will be migrating down-gradient and impacting the alluvial wells in a couple of years. Already, the groundwater at the West Ridge well, WR-1, exceeds the predictions of the PHC, so that, combined with the saline water contribution from unknown sources upstream will make a difference on that alluvial aquifer for a long time. Rule 4.15 - Reve¢etation 8. In Section 4.4 of the permit, P&M Coal Company commits to conducting interim revegetation monitoring this summer. DMG would like to observe the monitoring if possible. Please let us know when the monitoring will occur. Edna Mine Permit No. C-80-001 Midterm Review 5 June 7, 1999