BUREAU OF GEOLOGY 8. On-Site and Regional Monitoring Systems "Since the Mining Act addresses the full range of peat mining impacts, the Division of Land Resources should apply its provisions to require monitoring of the full range of impacts. These expanded requirements should be incorporated as conditions on the mining permit. Also, the Division of Environmental Management should continue to expand its ambient air, surface water, and groundwater monitoring system in the peat mining region. "Incorporation of surface water, air, and groundwater monitoring requirements in conditions of mining permits does not diminish the pri- mary role of the Division of Environmental Management in setting these requirements and in analyzing the results. An advantage of the package approach to permits for peat mines is that monitoring can be fully coordi- nated among the concerned agencies. The peat permit application review group should play a central role in this coordination. "As soon as the results of Skaggs and Gregory's peat hydrology pro- ject (See Table I) are available, they should be thoroughly evaluated by the Department and, where appropriate, incorporated in monitoring requirements. The surface and groundwater hydrology model developed by Skaggs and Broadhead may allow a predictive capability sound enough to relax some monitoring requirements. Even so, several years of very detailed monitoring results will be needed to verify the model. Fur- ther effort will be needed to expand the model for general applicability since it is presently rather site-specific for the 15,000 acre First Colony Farms site. "Since the task force's 1981 report, mercury in drainage water from peat mines has arisen as a major concern. In preparing their applications and analysis, PMA found mercury levels exceeding state standards in the waters receiving drainage from the First Colony Farms peat mine, and PMA reported their data to the state. Questions have arisen about the sampling and analytical methodology which produced these values, and a new sampling series has been proposed. PMA has not yet applied for nor received an NPDES permit for the First Colony Farms mine. "The mercury issue reemphasizes the need to require an NPDES permit for each peat mine. The department should require detailed analysis of mercury issue as part of each peat mining permit and NPDES permit application. All mining permits should require monitoring on-site and in receiving waters by the mine operator. Laboratory and field experiments should be initiated by the Division of Environmental Management, assisted by N.C. State University, to identify the chemical species of mercury present, mechanism of release, and transport mechanisms of mercury. These experiments should be supplemented with further and continuous biological monitoring by the Division of Environmental Man- agement and Marine Fisheries. Finally, the Division of Environmental Management should research to develop any needed water treatment standards for mine drain water. 146