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4 <br />1992, 1993, 1994 AHR Review <br />Bear Coal Company <br />March 30, 1995 <br />Page 3 <br />exceeded. The pond also discharged during the 2nd quarter and <br />six samples were taken. The first sample taken on April 5 <br />exceeded pH by 0. 1, and is shown on the Discharge Monitoring <br />Report (DMR). Two samples did not exceed any parameters. The <br />other three samples exceeded Total Suspended Solids (TSS) <br />(April 19, 40 mg/1; April 26, 40 mg/1; May 3, 80 mg/1). <br />However, these exceedances are not indicated on the DMR for <br />the 2nd quarter. The NPDES permit requires the operator to <br />report the 30-day average and the daily maximum for TSS. <br />According to the results of the discharged water provided in <br />the AHR, the 30-day average should be 31 mg/1 and the daily <br />maximum should be 80 mg/1 instead of 11 mg/1 and 20 mg/1 as <br />reported by BCC, respectively. The operator reported <br />discharging 30,000 gallons on the DMR and the AHR states that <br />54,000 gallons was discharged between March 29, and continued <br />through April 1993. So was 24,000 gallons discharged during <br />the 1st quarter? Also, the DMR reports the daily maximum at <br />a lower flow than the 30-day average, which is not possible. <br />Please have the operator respond to the above noted <br />discrepancies. <br />The pond did not discharge during 1994. <br />6. "nt" has been recorded for the water level of AA1 during 4th <br />quarter 1992. Please have the operator explain this notation. <br />7. pH and Conductivity data were not collected for any of the <br />springs, as required by the monitoring program. It appears <br />that the lab analysis were relied on for this data, and was <br />not included in the analysis. No lab analyses were provided <br />for G-26A in August or for G-26B in June and August. At a <br />minimum, field parameters, including temperature, should be <br />collected when flow measurements are obtained from May to <br />November. Please have the operator explain why this data was <br />not collected. <br />Ouality Analysis and Predictions <br />The operator states in the 1993 AHR that water quality in AA1 and <br />AA3 improved in comparison to previous years, with the exception of <br />conductivity. In 1994, the parameters remained consistent with the <br />data from 1993, with the exception of conductivity, which went up. <br />AA1 has not shown any significant degradation compared to AA3. I <br />believe the reason for the improvement in 1993 is due to the fact <br />that 1992-1993 had a high snowpack which yielded high runoff and <br />flushed the alluvium. I am not sure why the levels have remained <br />the same this year. The operator has included a couple of <br />