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2005 AHR REVIEW FOR MCCLANE AND MUNGER CANYON MINES With regard to surface water, we generally concur with the Division's previous findings that mine discharge will have a small impact on East Salt Creek. This is consistent with the Probable Hydrologic Consequences discussion in the permit document and the data reported in the 2005 AHR. Data presented in the 2005 AHR show that samples collected from East Salt Creek above and below the mine site are generally the same for all parameters. We have the following minor comments with regard to the surface water data presentation. 1. On page 5 of the AHR, CDPS Discharge Monitoring Reports are mentioned. Please amend the narrative to include a brief summary addressing the occurrence and nature of any CDPS effluent criteria exceedances during the water year, for any of the discharge points. ~i 2. Due to installation of Culvert P, mine water now enters East Salt Creek downstream from SW-1. Coordination of SW-1 sampling concurrent with mine dischazge events would provide useful information, and should be conducted as practicable. j With regard to groundwater, we recommend that the discussion in the AHR be expanded and the permit document(s) may need to be clarified or supplemented with additional information. The approved monitoring program for McClane includes wells GW-I and GW-3. The monitoring program for Munger includes wells GW-1, GW-3, and GW-6. Thee current approved programs include quarterly monitoring for field parameters only (temperature, pH, specific conductance, and static water level). Six alluvial wells were drilled and samples were collected for laboratory analysis during the period December 1977 through April 1979.1 Since the time of baseline data collection, apparently no samples have been collected for laboratory analysis. Field parameters only are measured for the wells in the current monitoring program. We have the following specific comments regarding the presentation and analysis of groundwater data. i 3. The baseline groundwater data for the Alluvial Wells No. 1 through No. 6 is presented in the McClane permit in Tables 4.2-1 through 4.2-5. There appears toy be some baseline data missing or possibly it was never collected. The current minimum requirements for baseline groundwater information are given in Rule 2.04.7 (1). No~ data are given in Table 4.2-1 through 4.2-5 for Alluvial Well No. 3 (possibly dry), and iron and manganese analyses are not provided for Alluvial Well No.s 5 and 6. No baseline data could be located for newer wells GW-7 and GW-8. i There is also uncertainty as to which of the original alluvial wells (for which baseline data has been provided) correspond to the wells in the current approved program. This needs to be clarified in the permits. In the Munger permit, Table 2.5-1 Mists groundwater monitoring site numbers and corresponding well numbers but this does not clear up the confusion regarding which of the "GW" wells were monitored during the baseline data program. For wells in the approved program, it is unclear if Alluvial Well No.s 1 and 6