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Responses to Division Concerns <br /> Page 7 <br /> The time available where meaningful information can be <br /> gathered due to snow cover , saturated ground conditions and <br /> sheet runoff from snowmelt is limited to approximately the <br /> third quarter of the year (mid-July through September) . <br /> Additional flow and metals data exists from SGC sampling <br /> records and the CDH Upper Animas River Study (1991 - 1992) <br /> that can also be used to evaluate main-stem creeks and a few <br /> of the inventoried adits. This data will be included in the <br /> initial water survey inventory report. <br /> SGC requests that the Poughkeepsie Gulch area be dropped from <br /> the area of study. This request is based on the distance from <br /> the Sunnyside Mine (down gradient from probable mine pool <br /> elevations) and a lack of geologic evidence that any conduits <br /> may exist in that directio- from the Sunnyside Mine. <br /> SGC also requests that the Division' s position that four <br /> quarters of inventory data be collected before valve closure <br /> be reconsidered due to the limited time available for <br /> collecting meaningful data as explained above and because of <br /> additional confidence that water that has passed through the <br /> Sunnyside Mine can be found due to the proposed use of a <br /> tracer as explained below. <br /> As suggested by the Division, a tracer feasibility study <br /> was performed for SGC by Simon Hydro-Search, Inc . This <br /> study evolved into a work plan after identification of <br /> bromide as a feasible tracer element. For additional <br /> assurance, this plan underwent peer review by Tracer <br /> Research Corporation. The work plan is entitled Work <br /> Plan to Perform a Tracer Test - September 3, 1993 and is <br /> attached for your review. <br /> i a,•. <br /> The key elements of the study and SGC' s proposal to use <br /> bromide as a tracer to detect waters that have passed <br /> through the Sunnyside Mine and appeared on the surface as <br /> seeps, spring, etc. are presented below. <br /> Y ` , <br /> Bromide is not significantly affected by precipitation, <br /> ' absorption or biological activity. It can be detected at <br /> levels of 0. 01 ppm and is not a regulated ground-water <br /> constituent. It is considered benign at the proposed <br /> concentrations (page 6 - Work Plan to Perform a Tracer <br /> Test) . <br /> Analysis for bromide has been included in the water <br /> survey. Background levels for all analysis received to <br /> date have been less than the detection limit of 0. 01 ppm. <br />