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<br /> <br />downstream site) and HGSD3 (new downstream site). Site HGSD3 had <br />replaced HGSD2, as HGSD2 was too far downstream and could have <br />picked up the effects of non-mining influences. The operator <br />continues to sample HGSD2 although it is not required. The <br />groundwater monitoring sites shown are HGDALI (up gradient <br />alluvial), HGDAL2 (old downgradient alluvial) and HGDAL3 (new <br />downgradient alluvial). Site HGDAL3 had replaced HGDAL2 as HGDAL2 <br />was not positioned downstream of all of the disturbance. Also, <br />HGDALI and HGDAL2 may have been completed in the Lewis Shale and <br />may not have been representative alluvial wells. Although not <br />required, the operator continues to sample HGDAL2. NPDES 001 is the <br />outfall for pond 1 (truck loop pond) and NPDES 002 is the outfall <br />for pond 2 (rail loop pond). <br />Page 7 of Tab 13 of the permit application contains the <br />requirements for the surface water monitoring frequency while Table <br />13-1, on pages 8 and 9 of Tab 13, shows the required field and <br />laboratory parameters to be analyzed. Surface water sites HGSD1 and <br />HGSD3 are to be sampled semi-annually. As shown in the 1994 AHR, in <br />Table 1 on page A-2, the required surface water monitoring program <br />had been followed. <br />The required groundwater monitoring requirements are also shown on <br />page 7 of Tab 13 of the permit application. The required field and <br />laboratory analyses are shown in Table 13-2 on pages 10 and 11 of <br />Tab 13. This information L`orresponds to Table 2, on page A-4, of <br />the 1994 AHR. The groundwater monitoring requirements were followed <br />in the 1994 AHR. <br />The NPDES permit can be found in Appendix 13-1 of the permit <br />application. The permit number is COG 850008 and it requires <br />quarterly Discharge Monitoring Reports for both ponds. Appendix C <br />of the 1994 AHR contains all required DMR's. The sampling <br />parameters required by the NPDES permit were analyzed when there <br />was a discharge. <br />2. Water Quantity and Quality Analyses <br />There were no laboratory analyses performed at HGSD1, the upstream <br />surface water site. There was no flow on 4/20/94 and the site was <br />flooded by an irrigation dam on 9/27/94, so no samples were taken. <br />There were no flows recorded on 9/27/94 for HGSD2 and HGSD3 as <br />well. However, field parameter and full suite laboratory analyses <br />were performed for HGSD2 and HGSD3 on 4/20/94. <br />A comparison of the laboratory data, found in Appendix B of the <br />1994 AHR, was made with the material damage suspect levels, found <br />in "A Description of the Material Damage Assessment Process <br />Pertaining to Alluvial Valley Floors, Surface Water, Ground Water <br />and Subsidence at Coal Mines", January 1988. The comparison shows <br />that manganese and selenium exceeded the compliance limits (.23 <br />2 <br />