REP28728

• Permit No: C1980005
• IBM Index Class Name: Report
• Doc Date: 8/20/1987
• Doc Name: 1986 ANNUAL HYDROLOGY REPORT SENECA II MINE FN C-80-005
• From: MLRD
• To: STEVE RENNER
• Annual Report Year: 1986
• Permit Index Doc Type: Hydrology Report
• Media Type: D
• Archive: No

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,_:
STATE OF COLORADO
Roy Romer, Governor
DEPARTMENT OF NATURAL RESOURCES
MINED LAND RECLAMATION DIVISION
DAVID C. SHELTON, Director
DATE: August 20, 1987
T0: Steve Renner
FROM: John T. Doerfer ply -i
RE: 1986 ANNUAL HYDROLOGY REPORT - SENECA II MINE - FILE N0. C-80-005
I have reviewed the Seneca II 1986 AHR you forwarded to me on Monday and we
received from Peabody Coal Company on May 15, 1986. The report is complete
and well organized. Peabody reacted favorably to the comments we made
following last year's AHR and have incorporated them into this year's report.
MY comments, which you may consider for inclusion in a response to Peabody on
the 1986 AHR, are provided below:
1. In the discussion on page 44 concerning Fish Creek water quality and
exceedance of standards, the statement is made that the Colorado
Department of Health has "arbitrarily" set drinking water standards for
this stream segment even though this water is not used for such
purposes. Also, it is stated that cadmium, lead, mercury, nickel and
silver are actually more stringent than drinking water standards. For
the purposes of clarification, the Water Quality Control Commission
established these standards because there is downstream use of water for
drinking water purposes (e.g., Milner, Hayden) and the metal standards
have been set to protect aquatic uses which require lower concentrations
than drinking water standards for these constituents. The assertion that
the standards established by the Department of Health were arbitrary is
incorrect.
2. A discussion is provided in the 1986 report on the commitment to verify
the HYMO model (Appendix G). An explanation is offered that the
comparison is not feasible due to limitations of the model. These
include the lack of a groundwater infiltration algorithm, pond storage
and withdrawals, and lack of comparable precipitation data between the
design storm and actual monitoring.
A request is made (p. G-1) to revise the permit text to remove this
commitment. The Sedimot II model is currently being used by Peabody for
drainage design. In considering this proposed revision, the option of
verifying the Sedimot II model should be reviewed by Peabody and the
Division based on the intended purposes originally stated prior to
deletion of the commitment. This consideration should be made at the
time the revision is submitted.
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. [phone]