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<br />Michael G. Attavilla <br />Seneca Coal Company <br />Page 8 <br />November 24, 1993 <br /> <br />Utilizing the equation Q=KIA and the data for 2001 presented in the table, the Division <br />obtains the following values 1,493 gal{day and 709 gal{day fur the Wadge Overburden <br />and Wadge Coal aquifers ,respectively. If SCC's calculations need to be modified, <br />please check to make sure that other discussions and calculations in Tab 17 are accurate. <br />In particulaz, please verify the discussions on pages 90 and 93, and the chemical loading <br />calculations on pages 93 and 94. <br />29. On page 116 of Tab 17, SCC states that the purpose of ponds 015, O l6, and O 17 is to <br />safely handle and treat runoff from a 100-yeaz, 24-hour storm (2.6 inches). Elsewhere in <br />text (page 2, Tab 18), SCC states that each pond has been designed to contain and treat <br />runoff from a 10-yeaz, 24-hour storm event. Please reconcile this discrepancy and <br />provide revised page(s), if appropriate. <br />30. Maps of the II-W South area show apre-mining stock pond in t)ae drainage above and to <br />the east of Pond 016. It appears that the pit excavation will remove this stock pond. The <br />Division recommends that SCC consider reestablishing this stock pond at this location. <br />Please provide a plan for replacement of the stock pond or provide an explanation if SCC <br />does not believe reestablishment of this pond is appropriate. <br />31. Surface Hydrology Map 13-2A indicates that additional disturbed area runoff from the II- <br />W South azea will flow to existing Pond 006. This additional inflow does not appeaz to <br />be accounted for in the Pond OOb modeling. If appropriate, adjust the hydraulic input <br />modeling information to Pond 006. <br />32. Drainage Basin Pond-017 azea is shown to be over 955 acres. This is a very large azea <br />with significant runoff volume in comparison to the much smaller area of disturbance <br />associated with the proposed year 2003 pit excavation. Has SCC considered other <br />alternatives to treating runoff from such a large area? For example, could Pond 017 be <br />moved closer to the disturbed pit azea outside of the Hubberson Gulch streamflow? <br />Please consider alternatives to treating runoff from this very lazge basin, which primarily <br />consists of undisturbed ground. <br />33. On page 2 of Tab 16, SCC states that increases in TDS of 41% and 255% aze possible in <br />the overburden and the coal aquifers. The Colorado Department of Health Basic <br />Standards for Ground Water has a maximum allowable TDS concentration of 1.25 times <br />the background level. It appears that the estimated increases in TDS will exceed the <br />CDOH standazd. SCC further states in Tab 17 that these increases will not have a <br />significant impact on surface water and groundwater. With the lack of downgradient <br />monitoring wells, How will SCC verify these conclusions? Please provide a proposed <br />plan for monitoring the overburden and coal aquifers downgradient from the disturbed <br />