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RESPONSE: Pages 2.05.6-17 and 2.05.6-18 as well as Exhibit 34, <br />• Summary of Dissolved Solids and SAR Data for the Williams Fork <br />River have been revised to address these issues. <br />g. As previously stated in the AHR Review, calcium, magnesium, .d <br />sodium should be added as parameters to the following monitoring <br />sites: <br />• WF-1 and WF-2 <br />• No. 5 and No. 6 Mine Discharges <br />These measurements should be conducted on a quarterly basis and analyzed <br />as total recoverable. All existing sites sampled for calcium, magnesium <br />and sodium need to have SAR calculated and included in the permit <br />application. It should be noted that the SAR's calculated from the 1980 <br />laboratory analyses (as found in the permit application) are over <br />• estimated and should be recalculated. <br />The Division realizes that discussions have been held over the matter of <br />SAR requirements for the above referenced monitoring sites. The <br />Division is still of the opinion that the SAR analyses are needed due to <br />the high SAR's present from waters of No. 5 and a well in the No. 6 Mine <br />coal seam. It was proposed by Empire Energy that any change in SAR <br />values would be identified by an increase in total dissolved solids <br />(TDS) levels. This is not sufficient for SAR depication due to the <br />number of chemical parameters that affect TDS. Also in the vicinity of <br />the mine, high SAR's are typically characterized by a deficiency of <br />calcium and magnesium and not significant increases in sodium. For this <br />reason, an increase in SAR would not necessarily be depicted by an <br />increase in TDS levels. <br />For the purpose of depicting <br />mining, the concentration of <br />• loaded into the lower flow <br />late/critical irrigation season, <br />probably hydrological consequences of <br />SAR level from mine pumpage should be <br />month's concentrations coinciding with <br />39-11 <br />