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Mr. David Beverlin - 2 - February 26, 1988 3. The approved surface water plan specifies instantaneous flow measurements will occur at sites TR-b and OK-a in conjunction with water quality sampling. However, as addressed in the AHR, this information is not being collected. Again, water quality data are incomplete without simultaneous flow data, P 8 M needs to commence taking these flow measurements. 4. A quality control check of the field electrical conductivity (EC) measurements compared against total dissolved solids (TDS) reveals this data collection needs to be improved. Typically, EC measurements equal or exceed TDS, whereas, the data reveals EC measurements average only 77% of the TDS concentrations. The meter should be calibrated against standards each time the meter is used. Also, the meter being used by P & M may not report EC at 25°C (specific conductance). Please indicate ~/ if the meter does do this or if conversions must be hand calculated. ,S~ In the past, a spring and seep survey has been submitted each January. / Please submit the results from the 1987 survey. Based on the detailed AHR, it is the Division's belief a number of changes should be made since some of the parameters being analyzed are far below standards and could be dropped; some of the parameters being analyzed are incompatible with existing standards or current environmental perspective on the form of analysis; and certain components at the Edna Mine are not being analyzed. The Division recommends the following items be included in a technical revision application to modify the existing hydrology monitoring plan. A. Arsenic, selenium, zinc, mercury, and dissolved oxygen may be dropped from the long parameter list since these parameters occur at levels far below applicable standards. e. A quality assurance check, using a mass balance evaluation between the major cations and anions, is performed by the Division to verify that acceptable full suite analysis occurs. As previously discussed with you, the Division performed such an analysis of the August, 1987 analysis and determined that it appeared there were analytical quality control difficulties. It turns out that where the TDS is less than 550 mg/1 and potassium and chloride are not analyzed, the mass balance methodology does not provide accurate results. (Table 1) Therefore, for those sites that historically have TDS values below 550 mg/1, potassium and chloride should be analyzed. C. Nitrogen speciation is unclear due to the current analysis of NO2-N03. To accurately assess the impacts, if any, of nitrogen, analysis should be performed for nitrite and nitrate separately. Also, for surface water samples, un-ionized ammonia should be analyzed.