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<br />3. Monitoring frequency, specific to laboratory sampling requirements, was met on a semi- <br />annual basis for the luppa well and on a quarterly basis for the Refuse well. <br />Water Quantity and Quality <br />No significant changes attributable to mining have occurred regarding water levels in the <br />two monitoring wells. Water quality shows no degradation affecting any probable use. <br />Total Dissolved Solids downgradient of the refuse pile have increased slightly but are <br />within the predicted levels. For reasons unknown at this time, the Refuse well <br />experienced a brief but substantial decline in water level in April of 1998. However, <br />water levels returned to normal levels within 60 days and no further deviations were <br />recorded during 1998. <br />5. Please submit a minor revision proposing the following modifications as necessary to the <br />hydrologic reporting requirements. <br />a. Due to closure of the mine, sites id 05, O6 and 07 have been eliminated. Please <br />provide a new surface water and ground water schedule (p. 552) that reflects the <br />elimination of these monitoring locations. <br />b. If appears that flow observations are being made quarterly on the permanent <br />diversion rather than weekly as required. What are Energy Fuels intentions to <br />comply with the approved plan of weekly visits to observe and/or sample any <br />flow? It seems apparent that a change in frequency to observe possible flows is <br />necessary. <br />c. Does the CDPS permit also require weekly visits to the sediment pond outfall to <br />observe pond discharge? If not, the frequency (weekly) should be change to <br />reflect actual requirements. Another possible option is to state in the schedule <br />that sampling of sediment pond discharges will be conducted in accordance with <br />the approved CDPS permit rather than trying to re-state the requirements in the <br />mining permit application. <br />d. The quarterly submittal requirement for water data was eliminated many years <br />ago. Please propose new language on page 554 to indicate that the "hydrologic <br />monitoring data will be submitted in an annual report no later than February 28 of <br />each year for the previous monitoring year' or similar language. <br />e. Although hardness for ground water data is being sampled and reported it is not a <br />requirement based on the sampling list on page 553. Please modify the list to <br />include hardness for ground water wells. <br />Please respond to the 1998 AHR review questions within 30 days of receipt of this letter. If you <br />have any questions, please call me. <br />Sincer ly, ^^ oo <br />Kent Gorham <br />Environmental Protection Specialist <br />CC: Dan Hernandez <br />