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Although the general trends shown in the above table and the table in the "Hydrological <br />Monitoring Results 2007-2009" section above seem to confirm Colowyo's statements regarding <br />the probable hydrologic consequences, it is important to note that there is still a good deal of <br />seasonal variability in the data. While the general trends are important, any single data point that <br />is looked at may be above or below the average or trend for any given analyte. <br />The PHC section of the Colowyo permit that discusses surface water states that there-will be very <br />slight to no impacts to the due to mining. It states that Colowyo will have no impact on the TDS, <br />electrical conductivity or flow. as a result of mining. A review of the shows that there is much <br />more seasonal variability than with the ground water, which is normal. While the general trends <br />for the TDS and electrical conductivity for the older wells (New Upper Good Spring Creek, <br />Lower Good Spring Creek and Lower Taylor Creek) show a slight upward trend in TDS and <br />electrical conductivity, the data is extremely variable (again, seasonally). The flow is also <br />extremely variable as a result of seasonal variability as well as variability due to the use of Good <br />Spring Creek for local agriculture. The Upper West Fork Good Spring Creek site is showing a <br />decrease in TDS and electrical conductivity but the data set is very small, as it has only been <br />sampled since 2008. Finally, Lower Taylor Creek has not flowed since 5 March 2001. <br />Spoil Springs <br />There is no discussion of spoil springs in either the Colowyo Annual Hydrology Reports or the <br />probable hydrologic consequences section of the Colowyo permit. It is important to note that <br />numerous small spoil springs have formed in the reclaimed East Pit area. These spoil springs <br />have appeared as wet spots along the outslopes of the reclamation, mainly in the Streeter and <br />Gulch A watersheds. The spoil springs are generally wet spots of a small size from seepage of <br />an immeasurable amount of water. They have been seen while walking the reclamation and <br />ditches and in aerial photography. None of the spoil springs that have been seen appear to be <br />flowing, just seeping. The Division has requested that Colowyo address these spoil springs in <br />their 10 May 2010 Midterm Permit Review. The Division asked the following question: <br />7. In the probable hydrologic consequences section of the Colowyo permit there is no <br />discussion regarding spoil springs. Numerous spoil springs have been identified by <br />both aerial photographs and on the ground inspections in the East Pit. Additionally, it <br />is assumed that the continual discharge from the Streeter Pond, even during the dry <br />summer months, is a result of a spoil spring(s). Please include a detailed discussion of <br />the spoil springs that have developed in the East Pit as well as those that are expected <br />to develop in the West Pit andthe South Taylor Pit. Please include a discussion of the <br />probable hydrologic consequences from these spoil springs, including discussions on <br />the anticipated changes in the quality and quantity of surface and ground water. <br />The Division has requested a response to this question (and other questions in the Midterm <br />Review) by 25 June 2010.