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Rob Zuber <br />Page 2 <br />December 9, 2016 <br />that Peabody is meeting this frequency. Please explain where this data is shown in the AHR <br />or why this frequency is not met. <br />For the sampling of receiving waters, the frequency meets or exceeds the requirement of semi- <br />annual sampling. <br />Springs are monitored annually, and this is in compliance with Tab 15, the Hydrologic <br />Monitoring Program in the PAP. <br />LIST OF WATER QUALITY PARAMETERS <br />For the NPDES sites, the Division believes that settleable solids as well as oil and grease should <br />be assessed in the AHR. Please explain why these parameters are not assessed in the AHR by <br />Peabody. <br />For site YSSF3, the PAP calls for monitoring the short list of parameters, but Peabody is <br />performing analyses for the long list. For other receiving water sites (YSS2, YSGF5, YSG5), the <br />long list was greatly reduced with TR -47 (2010), but additional parameters are being analyzed. <br />Please explain why additional parameters are being analyzed. <br />The PAP states that: <br />• The long list of parameters must be monitored for YSSPGI. <br />• For the three other spoil springs, the parameters on the short list must be monitored. <br />• Low flow springs are only monitored for field parameters. <br />Additional parameters were monitored for all of the springs. Please explain why additional <br />monitoring was performed. <br />COMPARISON TO WATER QUALITY STANDARDS <br />The standards in the 2015 AHR for agricultural use (Table 11) match the standards in CDPHE <br />Regulation 31 (Basic Standards and Methodologies for Surface Water). Additional standards in <br />the 2015 AHR (Tables 13, 15, and 17) match the standards in CDPHE Regulation 33 <br />(Classifications and Numeric Standards for the Upper Colorado River Basin) for segments 13e, <br />13i, and 13j. <br />