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<br />Michael G. Altavilla <br />Seneca Coal Company <br />Page 2 <br />March 22, 1999 <br /> <br />3. On page 9 of the AHR, SCC states that "the CDOH standard of 0.? mg/1 is used to protect <br />crops grown in soils with a pH value lower than 6.0. In soils with a higher pH (as are found in <br />the Seneca II region), a more appropriate standard would be l0 mg/1. (EPA, 1976)." Please note <br />that the Division could not find a CDPHE reference in "The Basic Standards for Groundwater" <br />regarding this statement. The appropriate agricultural standard for manganese in groundwater is <br />0.2 mg/1. <br />4. The Division agrees with SCC's findings that the percent TDS increases observed <br />between the upstream and downstream sites (SSF11 and SSF13) on Fish Creek are consistent <br />with the PHC predictions. However, the Division notes that a substantial TDS increase has <br />occurred at sites SSFI l and SSF13 on Fish Creek from June 1998 to June 1999. In June 1998 <br />and June 1999, the TDS concentrations at site SSFI l were 560 mg/1 and 1090 mg/1, respectively. <br />in June 1998 and June 1999 the TDS concentrations at site SSF13 were 640 mg/1 and 1120 mg/l, <br />respectively. These levels aze much higher than the predicted TDS concentrations. Has SCC <br />identified the source for the recent increase in TDS at sites SSFI l and SSF13? Please provide <br />the Division with your comments regarding the source of the appazent elevated TDS levels on <br />Fish Creek. <br />If you have any questions concerning the Division's review of the 1999 AHR, please contact me. <br />Sincerely, <br />M.u,~ac1 P~ Q <br />Michael P. Boulay <br />Environmental Protection Specialist <br />