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• Little Cr as sy and Grassy Creek and thus detected by the frequent monitoring at <br />surface water Site 002, SW-52-1, and SW-52-2. <br />Field parameters at Site GW-531-A2 and 33 will be collected on a semiannual basis at <br />the same time that the long suite water quality samples are obtained. Page 7-157 of <br />the Seneca II Permit Revision has been revised to incorporate the new sampling <br />frequency. A copy is attached to replace the existing Page 7-157 in the Permit <br />Application Package (PAP). <br />2. A discussion is provided pertaining to the Peabody Commitment to verify the HYMO <br />Model (Appendix C). An explanation is offered that the comparison is not feasible <br />due to limitations of the Model. A request is made (P. G-1) to revise the permit <br />text to remove this commitment. <br />The SEDIMOT it Model is currently being used by Peabody for drainage design. In <br />considering the proposed revision, the option of verifying the SEDIMOT II Model <br />should be reviewed by Peabody based on the intended purposes of the commitment. This <br />• consideration should be made prior to the revision submittal. <br />RESPONSE: <br />On F'a ge 7-77 of the Seneca II Permit Revision, Peabody stated that as more flow data <br />became available, verification of the HYMO Model would be possible. Page 7-174 restated <br />the above and indicated that the results of this verification exercise would be reported <br />in the 1986 AHR. Upon examination, the type of monitoring data being collected annot be <br />used for model verification. Most of the reclaimed area ponds being monitored are spring <br />and or ground water fed. HYMO does not have any subroutines that incorporate ground water <br />flow components. <br />Within the past year and a half, all drainage designs have been performed using SEDIMOT <br />II. Extensive and detailed monitoring analyses have been performed by the University of <br />Kentucky to demonstrate the applicability of the Model to coal mined watersheds. As in <br />the case of HYMO, the type of monitoring data being collected by Peabody cannot be used <br />for verification of the SEDIMOT II F1ode1. In light of the extensive studies performed by <br />the University of Kentucky and the general acceptance of SED IMOT II, it should not be <br />. necessary to attempt to further verify the Model. <br />The appropriate sentences of Pages 7-77 and 7-174 have been deleted on the revised pages <br />enclosed. Please replace the existing pages in the Permit with the revised ones. <br />