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f ~ <br />Mr. Grey Lewicki <br />Grey Lewicki and Associates <br />February 18. 1999 <br />Comparison of downstream and upstream surface water data. Historical and 1997-98 <br />data from the downstream site appear to not be sie ificantly different from data for the <br />upstream site. <br />8. Fulfillment of ground water monitoring requirements specified in permit. The 1997 <br />report contains the required full suite analysis from Pittsburgh and Midway's well TR-I.S, <br />located ?.2 miles downstream from Apex. The 1998 report contains selected parameters <br />from new upstream and downstream alluvial wells instead of data from the distant <br />downstream well, TR-1.5. With one exception (see following item the data meet the <br />requirements of the new ground water sampling program [hat began in 1998 as a result of <br />Technical Revision TR-9. Q <br />9. Omission of water levels From alluvial well data. The water level's in the alluvial wells <br />were not reported for 1998 as they are required on page 65.06 of the permit document. <br />Please submit these data or explain the reason for the omissions If you do not have them, <br />the Division considers that these one-time omissions do not seriously impair the monitoring <br />program. Please ensure water levels are submitted in future reports. <br />10. Comparison of reported ground water data with historical data. <br />Upstream - 1997 and 1998 samples taken from the new upstream site are consistent with <br />pazameter values reported for the old upstream site in 1980-81 beginning on page 65.32 of <br />the permit application. No vends in parameter values, upward or downward, are indicated. <br />Downstream - A valid comparison cannot be made between sample data obtained in 1998 <br />at the new downstream site, and the historical data from the old downstream site because <br />significant inFlows probably occurred along the 2.2-mile distance between the two sites. <br />11. .Comparison of downstream and upstream ground water data. Sample data from the <br />new downstream site generally do not appear to be significantly different from the data for <br />the old upstream site in 1980-8lbeginning on page 65.32 of permit. The pemuttee <br />expressed concern in the 1998 report about high iron and manganese levels in the <br />downstream alluvial water sample from the new well. Although those levels were high, <br />they appear consistent with the levels reported in the old upstream alluvial well reported in <br />the permit beginning on page 65.32. For example, the first manganese level reported in [he <br />old well was 1.39 mg/1, similar to the 1.58 mg/I reported in 1998 for the new downstream <br />well. Dissolved iron levels in the old upstream well widely fluctuated, reaching as high as <br />7.20 mg/t in one sample, significantly more than the 2.39 mg/1 reported for the new <br />downstream well in 1998. Nonetheless, special attention should be payed to future levels <br />of iron and manganese in the downstream alluvial well in order to determine if the high <br />levels reported in 1998 indicate a trend. <br />12. Achievement of Trout Creek's numeric standards set by Colorado Water Quality <br />Control Commission. Surface water sample data are insufficient to determine iF the Apex <br />Mine has had any inluence on most of the parameters that are in the standards. The <br />absence of discharge from the pond indicates surface runoff had negligible or no influence <br />Pale 2 <br />