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Page 6 <br />Overall, PHC predictions appear to be accurate, as illustrated <br />by the following examples. <br />Per the PHC, TSS values in the surface water runoff are <br />expected to increase a few years after mining and then decline. <br />Data for NPDES sites 001 and 002 illustrate this trend. <br />Per the PHC, elevated TDS levels will be detected in base <br />flows derived from backfill aquifers. During 2010, relatively <br />high TDS concentrations were reported for NPDES sites in <br />several gulches: Johnson, No Name, East Pyeatt, and Flume. <br />All four of these sites are downgradient of potential spoil <br />springs from the A Pit and East A Pit. In general, the data <br />reflect the inverse relationship between TDS and flow. <br />X. Agreement of <br />observed <br />hydrologic <br />CDRMS <br />Per the PHC, post -mine values of pH in surface water runoff <br />are not expected to be significantly lower or higher than <br />present or pre -mine levels. Field pH values for all sites in <br />2010 were similar to previous data collected. <br />impacts with <br />regulation <br />Yes <br />Per the PHC, Trapper does not anticipate recharge to the <br />PHC projected in <br />permit <br />2.05.6(3) <br />shallow aquifer systems to be adversely affected by mining <br />operations in the Third White Sandstone. Water levels in <br />wells GC -2, GP -9, and P -8 (used to monitor the Third White <br />Sandstone) did not rise or fall considerably between 2009 and <br />2010. Previous analysis has indicated good recharge with <br />above average precipitation over the last few years. <br />Per the PHC, constituent concentrations in backfill aquifers, <br />namely TDS and sulfate, are expected to be higher than pre - <br />mining concentrations for an extended period of time after <br />mining. The data for TDS concentrations in wells in backfill <br />aquifers have shown apparent impacts from mining. TDS <br />concentrations in GD -3 and GF -5 are somewhat higher to <br />those of native aquifers in these areas. TDS values for wells <br />GF -7 and GF -11 were much higher than the naturally <br />observed concentrations in the 1990s and 2000s, but have <br />declined in recent years. These trends have continued in 2010. <br />Sulfate concentrations exhibited similar trends as TDS for <br />wells GF -7 and GF -11. Sulfate concentrations increased in <br />GD -3 in 2010 and should be watched closely in future years. <br />Y. Adequacy of <br />CDRMS <br />groundwater <br />monitoring <br />program <br />regulation <br />4.05.13 (1) <br />yes <br />Z. Adequacy of <br />CDRMS <br />surface water <br />monitoring <br />regulation <br />yes <br />program <br />4.05.13(2) <br />Page 6 <br />