REP35015 - Laserfiche WebLink

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'- Water quality monitoring along Oak Creek is restricted to standard NPDFS parameters. Salinity and TSS do not appear to have increased hetween the upstream and downstream sites. Total iron concentrations generally exceed recommended aquatic life standards of 1.0 mg/1 and increase twenty percent at the downstream site. Dissolved iron concentrations are significantly less than the domestic water quality standard of 0.3 mg/1, which suggests that entrained iron-coated sediment is the cause of the iron concentrations. MLRD field monitoring in 1988 will attempt to pinpoint the source of this iron. Compliance with Hydrologic Monitoring Plan Compliance with the HMP involved a comparison of the submitted data with the plan found in Volume 11 on pages 4.6-139 through a.6-1alA and an evaluation of the quality of data recorded. I made the following observations: 1) P & M regularly performed surface water monitoring of field parameters six times a year rather than seven. I am very interested in obtainina_ water quality information durino all periods when the water is not frozen. As the Division has not commented on this in the past, I would recommend warning P R ~~ to monitor according to the conditions of their plan. 2) The current HMP calls for continuous flow monitoring six months of the year at the Koll ditch flume upstream of the site, an upstream Trout Creek site TR-a and on the Homestead ditch diversion downstream of the disturbed area. The operator submitted data which averaged monthly flow from the charts an average of five months a year during the last five years. In addition, the operator committed to instantaneous flow measurements at TR-b on Trout Creek and OK-a on Oak Creek in conjunction with their water quality sampling. P & M no longer appears to be reporting instantaneous flow data, following a P & M in-house decision about the utility of such measu rements. ~~The instantaneous flow records taken along Oak Creek (OK-a) and Trout Creek (TR-b) are not included in this report. This type of record gives only an instantaneous reading of the flow behavior of a stream at a given moment in time making it questionable as a good source of data for long-term ANR 1988 stream behavior." AHR ~~0p P & M does not appear to understand the philosophy behind the measurement of flow. Section 2.04.7(2)(b)(i) requests baseline flow evaluation to include "minimum, maximum, and average flows which identify critical low flow and peak discharge rates of streams sufficient to identify seasonal variations..." Section 4.05.13(2)(a)(i) states that "surface water monitoring during operations should he adequate to measure accurately and record water quantity and quality of the discharges from the permit area." This is elaborated further by the statutes (34-33-i22(2)(a)) which state "for those surface coal mining and reclamation operations which affect or potentially affect surface water or ground water, on or off the site the Division shall... require the permittee to establish monitoring sites to record the effect of the operations on the level and amount of such water."