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<br />The data in the AHR indicate that there has been no impact on water levels in the alluvium <br />of these two streams. <br />Review Concerns <br />Since early 2000, instantaneous flows have been reported on a twice a month basis <br />(at a minimum) for surface water sites SWGS 06 on Coal Creek and SWGS OS on <br />Jerry Creek. Permit narrative references quarterly instantaneous flow monitoring, <br />and reporting of estimated peak flows. The Division believes the monitoring that <br />has been conducted is adequate, and that no useful information would be provided <br />by continued reporting of estimated peak flows on the drainages. However, the <br />monitoring plan and schedule for the two sites needs to be amended to specify <br />monthly reporting of instantaneous flows, with reference to peak flow reporting <br />deleted. An acceptable amendment addressing this matter has been submitted by <br />the operator within TR-42, currently under review. <br />2. There was a significant apparent increase in TDS level for Well UTL-02 between <br />2001 and 2002. In addition, the relationship between TDS and conductivity for the <br />UTL wells in 2001 and 2002 was very inconsistent (2002 AHR Table GD-13). In <br />2001, Well UTL-02 TDS was approximately y: of conductivity, but in 2002 TDS <br />was over 2 times higher than conductivity. Does the 2002 result reflect an <br />analytical or reporting error? Please evaluate this data, and address the reasons for <br />and implications of the reported increase in the alluvial well TDS levels between <br />2001 and 2002. <br />The current monitoring plan annual surface water analytical list (Table 18-2) <br />specifies laboratory test for Total Soluble Major Ions and Total Soluble Heavy <br />Metals. Reporting of Dissolved Major Ions and Dissolved Heavy Metals would allow <br />for a more meaningful assessment of hydrochemical trends. Please submit a <br />technical revision to amend Table 18-2 accordingly. <br />