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October 29, 1992 <br />Pege 6 <br />TCC Response <br />It would appear that an improper file segment was imported for site <br />305 for 1990, which is in turn reflected by the graph. Concerning <br />the lack of fluctuation in 1991, part of the break is attributable <br />to the lack of data during periods of ice cover in conjunction with <br />a missing value. The figure will be corrected in the 1992 AHR. <br />DOMG Concern - Monitoring Freauenc <br />Bedrock Wells <br />1) TCC's approved hydrologic monitoring plan calls for a minimum of <br />two downgraient Wadge overburden wells to be monitored. It is <br />apparent after review of the data that the only wells in the Wadge <br />that were monitored in 1991 were 006-82-74C and 009-79-4. Water <br />quality information indicates 006-82-74C is contaminated by spoil <br />water from the upgradient surface mining activity. Review of Map <br />13, which represents the piezometric surface of the Wadge, shows <br />this well to be downgradient from longwall mining but isolated in <br />a depression of the piezometric surface. 009-79-4 is upgradient of <br />all active mining and shows water quality which is seasonally <br />indicative of expected Wadge water quality. Although unexpected <br />circumstances were the apparent cause of the loss of 006-88-2 and <br />006-87-1, water level data as well as sampling difficulties for both <br />wells did indicate potential future problems. <br />The Division's position is that TCC should anticipate wells that <br />will be potentially affected by mining and add additional wells <br />(downgradient in the case of the Wadge) to insure compliance with <br />their approved plan. Specifically, the downgradient area in this <br />case would be to the northeast of the current active underground <br />mining. <br />TCC Response <br />TCC wishes to clarify the following items: <br />1) TCC did in fact complete an additional Wadge overburden well <br />below 006-88-2, and re-habilitated well FBR-11-A after aquiring it <br />from P&M. Both of these wells were monitored in September of 1991, <br />but were not reported in the 1991 AHR as previously agreed upon <br />with the Division. Both parties at the time felt that delayed <br />reporting would be beneficial in order to begin with a greater <br />number of data points for interpretation. <br />2) Well 006-88-2 gave no indication of potential problems which <br />might prevent compliance until the May sampling episode. At that <br />time a casing separation was discovered which precluded collection <br />of the sample. Prior to that time it was assumed there would be no <br />