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soq�ENEc Coal company Seneca Coal CgWany 'm - V 6•v January 22, 2014 RE Colorado Department of Health WQCD -PE -132 TION 4300 Cherry Creek Drive South pl�S,pr� Or RECTA Denver, CO 80246 -1530 MININu FEND SAFEn RE: Quarterly Discharge Monitoring Report for Seneca Coal Company, Permit CO- 0000221 Dear Sir or Madam: Pursuant to the quarterly reporting requirements contained in Colorado Discharge Permit CO- 0000221 (Seneca CDPS Permit) for the Seneca Mine Complex, enclosed please find the fourth quarter 2013 discharge monitoring reports for Outfalls 005, 006, and 008 to 017. No flows were observed at Outfalls 005, 009, 011, 013, 014 and 015. All other Outfalls discharged continuously. During review of the enclosed DMRs, I discovered a problem with the units on several of the individual Outfall forms for the Iron, total recoverable (Fe TREC) parameter. The effluent limit for Fe TREC in the current Seneca CPDS Permit is 1,000 ug/L. However, the DMR forms for Outfalls 005, 006, 010, 011, 016 and 017 provided by the Water Quality Control Division list units for Fe TREC as mg/L, not ug/L as required by the permit. And, the DMR forms for Outfalls 008, 012, 013 and NMI -3 list the correct units for Fe TREC as ug/L. For several years, consistent with the Seneca CDPS Permit, Seneca has been reporting all number concentration values of Fe TREC on all DMRs submitted for the Seneca CPDS permit as ug /L. Accordingly, I have edited each of the enclosed fourth Quarter DMRs for which discharges are reported by drawing a line through the mg/L units associated with the Fe TREC reported values and hand - written the correct units of ug/L just below each strike - through. I contacted Leslie Simpson of the Division by telephone at about 9:25 am on January 22, 2014 and brought this issue to her attention. My understanding from our conversation is that the DMR forms are generated based on the ICIS database system. Leslie told me she will work towards repairing this problem in ICIS, and changing the units for Fe TREC for the Outfalls should correct all Fe TREC data submitted previously for these outfalls. Leslie also approved my plan to edit the incorrect units as shown on the enclosed DMRs. Lastly, I understand this error should be eliminated by the modifications to the ICIS system, and DMR forms that will soon be sent to me for the 2014 DMR submittals under the Seneca CPDS Permit will show the correct units for Fe TREC (ug/L). No excursions of DMR limits occurred during the fourth quarter of 2013. Please don't hesitate to contact me at (928) 913 -9218 or via email at jcochrangpeabod eY nergy.com if you have questions or need additional information. Si re o Cochran ager Environmental Hydrology Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 Telephone (970) 276 -5217 • FAX (970) 276 -5222