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Peabody Sage Creek Mining, LLC <br />Page 6 <br />8/25/2016 <br />• The Total Rec. Iron standard was exceeded in <br />June of 2015. <br />• The total Mercury standard was exceeded in <br />April and September of 2015. <br />• The Selenium standard was exceeded in March <br />of 2015. <br />It is unclear if the Mercury standard was actually <br />exceeded. The Method Detection Limit (MDL) for <br />Mercury is .2 ug/l and the stream standard is .01 ug/1. <br />Given this, the MDL is higher than the standard. <br />According to the AHR, there is a temporary modification <br />(expired December 31, 2018) of the Selenium standard as <br />"current conditions". Therefore, the excursion of the <br />Selenium standard is not considered an exceedance. <br />PSCM also claims that part of the high Selenium levels is <br />due to water received from Scotchman's Gulch, which is <br />in contact with the Lewis Shale which contribute to high <br />Selenium values in many of the streams in the area. <br />PSCM claims that the Iron excursion was a result of high <br />suspended solids and noted that no excursions occurs at <br />NPDES sites. However there was an exceedance of Iron <br />observed in NPDES 003 in October of 2014, but there <br />was not an exceedance in June of 2015 which is when <br />there was an exceedance observed at site YSG5. <br />According to the AHR, the detection limit for Ammonia <br />is .05 mg/l and that all values above the detection limit <br />are compared to the table standard on page 87 of the EPA <br />website: http://nepis.epa.gov/Adobe/PDF/20003O3L.pdf <br />Based on this table it does not appear the ammonia limit <br />was exceeded given the temperature of the water and the <br />pH at the time of sampling. <br />Mercury exceedances: <br />According to page 22 of the 2015 AHR, the Colorado <br />Department of Public Health and Environment performed <br />a reasonable potential analysis on PSCM's outfalls and <br />determined that there was no reasonable potential for <br />PSCM's outfalls to exceed the Mercury limit; therefore, <br />