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RESPONSE TO DMG CONCERNS PAGE 2 <br /> will eventually make its way to the surface as part of the <br /> reestablished natural groundwater regime. Its presence in <br /> Cement Creek within five years would be evidence that water is <br /> escaping from the mine workings to the surface. SGC originally <br /> proposed that it monitor Cement Creek for the presence of <br /> bromide for five years; if the bromide tracer were detected <br /> within that time, SGC would take appropriate steps to locate <br /> and shut off the source of the escaping water. Such steps <br /> might include draining the mine pool (with appropriate <br /> treatment of the released water) . <br /> In response, DMG proposed that SGC conduct monitoring program <br /> of sampling, surveying and analysis, including a study of the <br /> conjunctive flow regime of Cement Creek, to determine whether <br /> the bulkhead installation has caused increased water flows in <br /> the Cement Creek drainage. The October 15 letter does not <br /> state the proposed duration of the monitoring program. Rather, <br /> it states that the monitoring and inspection programs are to <br /> continue "as long as they can yield useful and pertinent data <br /> on the impacts of mine flooding. " <br /> In response to DMG concerns, SGC now proposes to monitor the <br /> Cement Creek drainage, for conjunctive flow volume and for the <br /> presence of bromide tracer, for a period defined by the <br /> buildup of water in the mine pool. SGC will track the rate of <br /> rise in the mine pool, and will monitor surface waters for two <br /> years beyond the point at which the rate of rise of the pool <br /> levels off. Levelling off will be defined mathematically; the <br /> formula and relevant factors will be mutually agreed to <br /> between SGC and DMG. <br /> SGC's proposal will allow DMG to issue the TR-14 permit <br /> revision with definite monitoring criteria. Such criteria <br /> would include a reasonable date beyond which monitoring will <br /> no longer be required. They would also specify objective <br /> points at which the predicted behavior of the plug and the <br /> mine water pool would be compared with the observed data; if <br /> observation conforms with prediction (within standard <br /> statistical norms) at the point where the mine pool buildup <br /> levels off, then DMG would release SGC from further monitoring <br /> requirements after the passage of another two years. <br /> Finally, the October 15 letter states that WQCD "may" have <br /> additional requirements that it wishes to impose on SGC. SGC <br /> has always been, and remains, willing to work with DMG and <br /> WQCD to insure compliance with clean water laws and valid <br /> regulations promulgated thereunder. However, SGC cannot accept <br /> as permit conditions the obligation to comply with undefined <br /> requirements. <br />