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<br />A. Surface Water Monitorin <br /> <br />The Division's concerns that TDS appears to be increasing downstream <br />of the loadout was addressed by Peabody but the explanation appears <br />to center on noise being generated by possible TDS inflo s <br />downstream of the upper monitoring site and upstream of the loadout~l <br />The Division would like to move the upper (and perhaps downstream) <br />surface water monitoring sites closer to the loadout facility to <br />reduce the amount of noise from outside sources. <br />Peabody understands the Div ision'a concern but has the following <br />concerns related to moving the surface water monitoring sites: <br />it has been Peabody's experience at Seneca II-W that TDS <br />increase downstream on Dry Creek even in the absence of <br />a mining related disturbance. Sometimes even with high <br />frequency sampling (numerous sites), trends are hard to <br />delineate. <br />2. Displacement of either of the monitoring sites will <br />result in a loss of sampling continuity which might take <br />five years to resolve. <br />3. Statistical analysis of the differences between the two <br />sites may not show a significant difference. Also, the <br />lab techniques used for analyzing HG's samples were in <br />a state of flux and may not represent hard data. <br />4. Peabody has the most reservation concerning of movement <br />of the downstream site as loading of coal ie just now <br />commencing and we could lose continuity when there ie <br />less chance of agricultural contributions to the sample. <br />5. Peabody will comply with the Division'6 decision. <br />6. Peabody's explanation for higher TDS values for the <br />Railroad Pond are educated guesses. No one has sampled <br />for the possible effects of 1) the pond intercepting the <br />Lewis shale or 2) the pond being influenced by <br />surrounding salt contributions. <br />Monitoring of Alluvium <br />The Division has a concern that 1) the two established sites do not <br />represent upgradient or downgradient conditions at the site, 2) that <br />they might be contaminated by drilling into the Lewis Shale and 3) <br />that the relative contributions of TDS by Stokes Gulch (which <br />parallels the loadout) and Dry Creek are not known. The Division ie <br />considering requesting relocation of wells and perhaps additional <br />wells to be established. <br />Peabody agreed with problems in the current system but had the <br />following concern: that these alluvial waters are of such poor <br />quality, lacking any potential use, that perhaps they do not need to <br />be monitored (particularly as any contributions by the loadout <br />should be limited or even beneficial). Peabody agreed to comply <br />with the Division's decision. <br />14. Alfalfa in the Seed Mix <br />(Please see Janet einns memo dated 3-31-93) Peabody agrees tc <br />substitute M. falcata for M. sativa or substitute a native legume. <br />