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<br />-~- <br />Comments/Recommendations <br />TL,... .. -ir ..J •- L. _JJ.____-J L. l..l 11 <br />.J <br />1. Since establishment of baseline monitoring P&M's monitoring program has <br />been decreased to a minimal level. This program does not easily allow for <br />detection of slowly developing trends, however this is not a problem at this <br />time. The water quality in Trout Creek is good, especially during periods of <br />irrigation. The worst water quality occurs in the fall and early spring just <br />prior to runoff and this quality is within acceptable limits. Following are <br />my comments on the current monitoring program. <br />a, According to the present program, P&M should be monitoring all sites <br />for water levels and field parameters every month except December, <br />Januaryary a~Fe~ruary. In addition to the above mentioned months, P&M <br />has not been monitoring in November or March. If sampling is not <br />possible at these times then P8d~i needs to report this in their quarterly <br />monitoring results and/or request a change in their monitoring program. <br />b. As part of their permit application, PBdd committed to water quality <br />monitoring at several additional locations (TR-E, a site to be <br />established in the draw between West Ridge and Center Ridge, and the <br />sediment ponds). The Division has received no information from these <br />sites. This information should be submitted to the Division. <br />c. Surface water site TRC should be reinstated into the monitoring <br />program this year. TRC is located in close proximity to the headgate <br />for the Homestead Ditch and should be a good indicator of the quality of <br />water entering the irrigation ditch. <br />d. The present monitoring program requires a full suite analysis <br />during runoff at the mine site but before runoff begins upstream from <br />the mine (least dilution effects), 2 months later during peak runoff <br />(greatest dilution effects) and in late fall just before winter freeze. <br />The second reading is indicative of the best water quality of Trout <br />Creek and is not a period of concern, I propose a change in monitoring <br />from that time to late August when the waters of Trout Creek will most <br />likely heavily be used for crop irrigation. <br />e. Water levels must be recorded from alluvial wells when field <br />parameters are taken. If this data has been recorded it has been <br />infrequently reported to the Division. If these records are available <br />they must be submitted to the Division. Future quarterly reports must <br />include water levels in alluvial wells. <br />f. All changes in the monitoring program must be submitted to the <br />Division as a technical revision. <br />