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c) It strains credulity that only one measurable flow event <br />(recorded April 15) occurred during the year at any of the gaging <br />locations. It would seem that some explanation should be provided. <br />If the problem is primarily due to the unreliability of the <br />sampling tubes and gages, it would appear that a modified design or <br />revised sampling approach is warranted. <br />I have some question regarding what we gain from continued <br />monitoring of Red Wash, Red Wash tributary, and Scullion Gulch, <br />even if the crest gage samplers did work. I think we know that the <br />drainages flow occasionally in response to storm events, and when <br />they do flow the water is typically high in suspended sediments. <br />Does the monitoring program serve some purpose with respect to the <br />PHC, or should it be discontinued or modified? <br />Ground Water Monitoring <br />1. Quarterly water level monitoring was apparently conducted at all <br />required bedrock ground water wells as specified on Table II.C-11, <br />with two exceptions. The table still lists Site 2-12U, however <br />text on page 5 of the AHR indicates that in 1987 the location was <br />subsided and the monitoring plan was subsequently amended to <br />eliminate monitoring of 2-12U. The table should be amended to <br />reflect the current status. <br />Secondly, the table lists site 2-17M and site 2-17L as required <br />monitoring sites, but data was reported in the AHR only for 2-17L. <br />Page II.C-74 of the application states that "monitor hole 2-17L was <br />cemented in October of 1985 as the hole was bypassed by mining. <br />The hole was cemented to prevent rapid discharge of water from the <br />hole into the mine workings. This monitor hole was replaced by <br />drilling and completing a new hole in 1986 in the general vicinity <br />of the other 2-17 holes." Explanation is needed as to how 2-17L <br />was monitored in 1996 if it was cemented in 1985. Was the new hole <br />drilled to replace 2-17L also designated 2-17L? q-~~,~.»~i~~~ Z <br />Although the table lists site 2-17M, no monitoring data is reported <br />for this site in the AHR, and there is no explanation in either the <br />AHR or the permit application text as to why 2-17M has not been <br />monitored. An explanation will be necessary. <br />2. Wells in leases C-8424 and C-8425 were monitored only twice, but <br />this is in accordance with the permit, as monitoring of these <br />locations had been suspended until April, 1996. <br />3. Monthly water levels and field parameters for Well Qal-5 are <br />reported in Appendix E, along with quarterly water quality <br />laboratory analyses. The data appears to be complete, however in <br />several instances carbonate and various heavy metals were "analyzed <br />but not detected". Should detection limit be reported? <br />