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1992, 1993, 1994 AIfR Review Bear Coal Company April 19, 1995 Page 3 quarter. A sample was taken on March 27, 1993 and no parameters were exceeded. The pond also discharged during 2nd quarter 1993 and six samples were taken. The first sample taken on April 5 exceeded pH by 0.1, and is shown on the Discharge Monitoring Report (DMR). Two samples did not exceed any parameters. The other three samples exceeded the Total Suspended Solids (TSS) standard (April 19, 40 mg/1; April 26, 40 mg/1; May 3, 80 mg/1). However, none of these exceedances were indicated on the DMR for the 2nd quarter. The NPDES permit requires BCC to report the 30-day average and the daily maximum for TSS. According to the results of the discharged water provided in the AHR, the 30-day average should be 31 mg/1 and the daily maximum should be 80 mg/1 instead of 11 mg/1 and 20 mg/1 as reported by BCC, respectively. BCC reported discharging 30,000 gallons on the DMR and the AHR states that 54,000 gallons was discharged between March 29, and April 1993. Please clarify if 24,000 gallons were discharged during the 1st quarter. Also, the DMR reports the daily maximum at a lower flow than the 30-day average, which is not possible. Please respond to the above noted discrepancies. 5. "nt" has been recorded for the water level of AA1 during 4th quarter 1992. Please explain this notation and include the reference in the AHR. 6. pH and Conductivity data were not collected for any of the springs, as required by the monitoring program. It appears that the lab analysis were relied on for this data, and was not included in the analysis. No lab analyses were provided for G-26A in August or for G-26B in June and August. At a minimum, field parameters, including temperature, should be collected when flow measurements are obtained from May to November. Please explain why this data was not collected. Quality Analysis and Predictions 1. The 1992 AHR report states, "although ground water test data is elevated over the previous year, it appears it was not due to conditions associated with the mining operations at the Bear ~3 Mine". This statement contradicts a letter BCC sent to the Division in 1990 regarding the possible cause of the degradation, which noted Bear's operation as the probable cause, and information contained in the permit on page 2.05- 55b. Therefore, this statement referenced should be revised in the 1992 AHR. Please provide a revised page.