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III IIIIIIIIIIIIIIII <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparimenl of Natural Resources <br />1313 Sherman 51., Room 215 <br />Denver, Colorado 80203 <br />Phone: 1303) 866-3567 <br />FAX: 1303) 832-8106 <br />TO: Erica Crosby <br />FROM: Jim Bume <br />SUBJ: Seneca II-W 996 Annual <br />Hydrology Report <br />30 December 1997 <br />~~~ <br />DEPARTMEM" OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames 5 Lo<hhead <br />Execmive Direarn <br />Michael 8. Lon¢ <br />Division Dneaor <br />Erica, I have finally completed review of the 1996 AHR for Seneca II-W. Comments are not <br />extensive, but are included below. <br />Generally, the AHR is ahigh-quality document, containing the necessary infom3ation for <br />analysis. It could be improved by two means. <br />One, the operator could actually relate the results to the PHC section of the permit. Afrer all, <br />isn't the purpose of the AHR to track confonnance of actualy conditions with predicted? <br />Secondly, the operator could use the same scale on the plots where possible. Some are way out <br />of the range of others, but for our purposes, variation in TDS content of 100 mg/I at a given <br />sampling location is not significant compared to variations of 2 or 3 orders of magnitude, the <br />range over which we are observing changes at some locations. <br />These are just suggestions. <br />Regarding the conformance of the hydrologic system to the predictions in the PHC, 1 have a few <br />comments. <br />Surface Water <br />The quality of the water in the Hubberson Gulch'`system" and the Dry Creek '`system" have not <br />reached the high dissolved salts levels predicted in the permit. At Hubberson Gulch, the water <br />downstream of NPDES point 006 has increased about 2~0 mg/I, but has reached a maximum on <br />one occasion of only 1700 mg/I -much less than Ithe predicted post-mining concentration of <br />2200 mg/I. Most measurements indicate levels about 830 mg/I. At Dry Creek, the NPDES <br />discharge point has seen water increase from l 100 Ing/l to nearly 1 X00 mg(I, but the at the <br />monitoring site downstream of the confluence of that tributary with Dry Creek, the <br />measurements have to this point fallen within the historic range, 1000 mg/I less than predicted. <br />The Sage Creek "system" is actually exceeding [he TDS loading predicted. Although <br />concentrations measured have displayed a wide range of values, the high has reached 710 mg/I <br />whereas the predicted maximutn for post-mining water is 465 mg/I. <br />