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7. See detailed comments by Hall & Associates regarding mercury. <br /> 10.a. Accelerated monitoring should be triggered b a 2 TU rather than a 1 TU because <br /> �� Y of the <br /> dilution in Dredger Cut. See comment 5 above. <br /> 11. See Comment 3 above. Numerous reports are listed in the permit as -being required <br /> within 90 days. It would be very difficult to complete all these reports concurrently. We ask that <br /> 270 days be allowed for evaluating the adequacy of existing wells. <br /> 12. Numerous reports are listed in the permit as being required within 90 days. It would be <br /> very difficult to complete all these reports concurrently. We ask that 180 days be allowed for <br /> submitting a mineralization plan. <br /> MONITORING AND REPORTING PROGRAM <br /> Effluent Monitoring <br /> Metals should be monitored as dissolved rather than total recoverable as per Comment 6 above. <br /> Receiving Water Monitoring <br /> Station R-1 as called out is in the discharge channel, not Dredger Cut. <br /> As commented before, proposed Station R-5 is at an extremely difficult location to reach for <br /> sampling because of no shoreline access. There is no special technical basis for the R-5 location <br /> proposed in the tentative permit. We propose moving R-5 further west near the Upland Canal so <br /> that we could have public road access for sampling. (See attached map) <br /> MONITORING ATTACHMENT A- 1VIAP <br /> We suggest that location D-1 from the Water Quality Impact report be sho«n on this figure for <br /> reference purposes. <br /> ATTACHiVIENT B - CEASE AND DESIST <br /> A cease and desist order is neither proper nor necessary. See Comment 1 above. <br /> ATTACHMENT C - FACT SHEET <br /> II. REGULATORY BASIS FOR REQUIREMENTS <br /> b) Dissolved Oxvsen <br /> Please note that R-1 is in the effluent channel, not Dredger Cut, and that dissolved oxygen <br /> measurements at R-1 are not reflective of Dredger Cut. Studies completed to date do not indicate <br /> that discharges may cause dissolved oxygen violations in Bishop Cut. <br /> tentcommentsw95 Exhibit I Page 7 12/17/99 <br />