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Sandra Brown <br />March 7, 2012 Page 8 <br />BCC is required to submit an Annual Hydrology Reports (AHR) to the Division in the beginning <br />of each calendar year for the previous year. Based on our review of these reports it is evident <br />that the water discharging from the hillside seep is of relatively good quality. BCC samples <br />upstream and downstream surface water monitoring stations on the North Fork of the Gunnison <br />River for semi - annual field and laboratory analyses, as well as annual full suite analyses. These <br />sample results show that the mine including discharge from the hillside seep have not had a <br />significant negative impact on the river. To illustrate this point I compared the upstream and <br />downstream sample data presented in the 1996 AHR with that of the most recent data available <br />data from the 2010 AHR (BCC has not yet submitted the 2011 AHR). These comparisons are <br />given in Attachment 5. The 1996 data show water quality results prior to the development of the <br />seep (seep first developed in November 1997). If the seep which continues to flow was having a <br />serious impact on the river it would be evident in the more recent sample results. As can be seen <br />from the data there is virtually no difference in water quality from pre -seep development to <br />present day. Also there are only minimal differences between upstream and downstream results <br />for both timeframes. <br />In reviewing the field and laboratory analysis presented in the 2010 AHR (the Division has not <br />received the 2011 AHR), the Bear No. 3 Mine had no significant deleterious effect on the North <br />Fork of the Gunnison River during the 2010 reporting period. The results of the hillside spring <br />water and the hillside spring water treatment pond sampling show that the treatment pond was <br />reducing iron concentrations in the spring water and that iron concentrations were in compliance <br />even before treatment. The seep water flows through a very small wetland area containing cat <br />tails before being piped to the treatment pond. There is not a significant amount of iron in the <br />discharge. Be that as it may, the level is being further lowered due to the action (uptake) by the <br />cat tails. There appears to be no settling out of the iron by the treatment pond. There may be <br />some precipitation, due to oxidation, but that would be readily visible as "yellow boy ". The <br />outflow of the treatment pond shows an increase in pH above the levels seen in grab samples <br />from the seep discharge. This could possibly be due to the cat tails removing constituents in the <br />seep water that would normally lower pH, thereby increasing pH in the treatment pond. TSS <br />values also were in compliance, but generally increased after flowing through the treatment <br />pond. There was no apparent trend with TDS values before and after pond treatment. All of the <br />WET testing of the hillside spring water and the discharge from the hillside spring water <br />treatment pond passed. The CDPS Discharge Monitoring Reports (DMRs) are available and <br />were reviewed for 2011 for the treatment pond outfall. The average flow from the pond was <br />calculated to be 3.6 gpm utilizing all values for 2011. The pond receives precipitation, snowmelt <br />and runoff, and probably some inflow from the underlying alluvium. The pond discharges <br />constantly and it is expected that discharge from the treatment pond is greater than the discharge <br />from the hillside seep. The treatment pond outflow was in compliance with all CDPS limits <br />except for pH which was slightly elevated as described above. <br />To illustrate what effect, if any the seep water would have if directly discharged to the North <br />Fork of the Gunnison River, I did a simple mass balance equation using iron and temperature <br />data for the seep combined with the North Fork of the Gunnison River water using data taken <br />from the upstream sample site. The most recent available data are utilized from the 2010 AHR. <br />In order to evaluate the potential impacts of the seep discharge, it is necessary to combine the <br />