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The Division has no further concerns. Oxbow preferred to not make any changes. Oxbow explained that <br />the Exhibit 2 summary table had information on wells 1321) and B2D2. Also, information from wells B- <br />2 and B-3 are for the appropriate Federal agencies and should remain in the text portion of the AHR. <br />16. Surface water locations S-1, C-1 and H7V-1 are to have monthly flow and field parameters sampled, as <br />well as full suite analyses in the 2" d and 3'*d quarters, if available. It appears that Oxbow performs the <br />full suite analyses in June and August of each year for the sites where this sampling is required. For <br />most of these sites, enough water is available during these two months to perform the full suite analyses. <br />However, at sites S-1, C-1 and 117V-1, the historic data shows that no water is available during June and <br />August, yet water is available during May. The Division requests that Oxbow attempt to perform the <br />required 2,d quarter full suite analyses in May at surface water sites S-1, C-1 and HN-1. <br />The Division agrees with Oxbow Mining that a `no flow' situation still is data. However, the full suite <br />analyses are an important part of water sampling. Oxbow has agreed to consider the Division's request <br />to sample earlier in the second quarter. <br />Compliance With Surface Water Standards <br />Examination of the 2007 AHR surface water information shows that there were no exceedances of receiving <br />stream standards at any of the surface water monitoring sites. There were no trends that would suggest that the <br />chemical constituent concentrations were increasing over time at each monitoring station nor were they <br />increasing from the up gradient monitoring station to the down gradient monitoring station. In summary, the <br />Division agrees with Oxbow Mining's conclusion that mining has not negatively affected the surface water <br />hydrologic regime. <br />Compliance With Ground Water Standards <br />The review of the 2007 AHR ground water information shows that there were no exceedances of ground water <br />quality standards. There were no indications of any developing trends towards exceedances of water quality <br />standards as well. Nor were there any problems with water levels in the monitoring wells. The Division agrees <br />with the conclusion of Oxbow Mining that there were no adverse effects on the ground water regime as a result <br />of mining activities. <br />If you have any questions, please let me know. <br />Sincerely, <br />Joseph . D? sh <br />nvironmental Protection Specialist <br />cc: Marcia Talvitie (DRMS-Durango) <br />c:/word2007/elkcreek/2007ahradeg2 <br />4