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The application text describing AHR;data collection and reporting indicates that <br />monitoring and reporting of field parameters for mine inflows would be conducted, <br />however this monitoring is not specified,in the ground water or surface wat~r monitoring <br />sections of the application, and the data has apparently not been collected iit•the past. <br /> <br />From an environmental impact perspective, it is the quality of mine effluent water that is <br />of concern. It is unlikely that influent water quality would be the cause of elevated <br />parameters in mine dischazge waters, and the primary value of influent water quality <br />monitoring would be as a "safety check" for the operator, in the event that effluent water <br />quality problems should develop in the future. As such, the decision regarding influent <br />water quality monitoring can be made at the operator's discretion. If the operator wishes <br />to delete influent water quality monitoring, the applicable permit narrative should be <br />modified accordingly; otherwise, influent water quality monitoring should be conducted <br />as described, and the water monitoring sections of the permit should be amended to be <br />internally consistent. <br />2. Water quality data was reported for numerous parameters as "analyzed but not detected". <br />The report should be amended to include pazameter detection limits, and detection limits <br />should be reported in futwe AHR's. <br />Appendix A, Page A-2 of the AHR, indicates that surface water monitoring sites would °~ <br />be monitored monthly, as soon as possible following significant rainfall events, for crest - <br />stage and field parameters. This monitoring program was discontinued pwsuant to a ~ ~~ <br />recent revision, and the change will need to be reflected in futwe AHR's. -=.f': <br />The permit application on Page II.C-77 indicates that groundwater data will be submitted <br />quarterly to the regulatory authority. Quarterly submittal of monitoring data is not - <br />necessary, as long as the data is available at the mine site; submittal of monitoring data in _ <br />the annual hydrology report is sufficient. Modification of the application text to specify <br />annual reporting would be appropriate. <br />5. Quarterly water level monitoring was apparently conducted at all required bedrock <br />groundwater wells as specified on Table II.C-11, with two exceptions. The [able still lists <br />Site 2-12U, however text on page 5 of the AHR indicates that in 1987, the location was <br />subsided and the monitoring plan was subsequently amended to eliminate monitoring of <br />2-12U. The table should be amended to reflect the current status. <br />Secondly, the table lists Site 2-17M and Site 2-17L as required monitoring sites, but data <br />was reported in the AHR only for 2-17L. No monitoring data is reported for 2-17M, and <br />explanation is requested. Also, Page II.C-74 of the application states that "monitor hole <br />2-17L was cemented in October of 1985...This monitor hole was replaced by drilling and <br />completing a new hole in 1986 in the general vicinity of the other 2-17 holes." Was the <br />