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existed in the creek during those quarters, or that there was no flow when EFCI did their quarterly monitoring. During the Mid-term review in 1993, EFCI was asked to elaborate on this issue(question No.13 of the Adequacy Review), which they did, with their response received along with a commitment to expend extra effort at attempting to catch flow during storm events. Their response explained that since the creek is ephemeral, flow at the mine sampling site occurs only during storm events, or when discharge from Pond No.2 is initiated, therefore, unless personnel are sampling during a storm event, it is likely no surface flow will be present in the creek channel. Upstream waters are removed via a pipeline by the town of Florence, so the storm event also needs to be localized within the mine site area for sampling purposes. Occasionally, in the months of July and August, large storm events do occur and the operator has committed to putting forth extra effort to catch the flow with sampling equipment at these times. STIPULATION N0. 15 THE OPERATOR SHALL MONITOR FLOWS IN SECOND ALKALI CREEK SO AS TO MEASURE MINIMUM AND MAXIMUM FLOWS DURING EACH QUARTER FOLLOWING APPROVAL OF PERMIT REVISION NO. 1. DURING THE MONITORING YEAR, AT LEAST ONE GRAB SAMPLE SHALL BE COLLECTED WHEN STREAMFLOW IS PRESENT. THIS SAMPLE SHALL BE SUBMITTED FOR LAB ANALYSIS FOR TOTAL DISSOLVED SOLIDS, TOTAL SUSPENDED SOLIDS, pH, TOTAL DISSOLVED IRON AND MANGANESE. RESULTS OF THESE ANALYSES SHALL BE SUBMITTED TO THE DIVISION WITHIN 60 DAYS FOLLOWING THE END OF THE FIRST MONITORING YEAR WHICH ENDS ON JUNE 30, 1992. Status - On-going The 1991 AHR indicates that there was no water in Second Alkali Creek on six sampling dates in six quarters following the issuance of the Permit Revision. It is not clear whether flow actually never existed in the creek during those quarters, or that there was no flow when EFCI did their quarterly monitoring. The response from EFCI via Technical Revision No.15 has been approved, as is addressed in Stipulation No.14's status above. STIPULATION NO. 16 WITHIN 30 DAYS OF APPROVAL OF PERMIT REVISION NO. 1, THE APPLICANT SHALL SUBMIT TO THE DIVISION THE FOLLOWING DEMONSTRATIONS FOR THE SMALL AREA EXEMPTIONS WITHIN THE PERMIT AREA: 1)A DEMONSTRATION THAT SEDIMENT PONDS OF TREATMENT FACILITIES ARE NOT NECESSARY FOR DRAINAGE FROM THE AREA TO MEET EFFLUENT LIMITATIONS, AND 2) A DEMONSTRATION THAT THE AREA IS SMALL AND THAT THERE IS NO MIXTURE OF SURFACE DRAINAGE WITH MINE WATER DISCHARGE. 7