REP29649

• Permit No: C1980005
• IBM Index Class Name: Report
• Doc Date: 9/2/2005
• Doc Name: 2004 Annual Hydrology Report Review Letter
• From: DMG
• To: Seneca Coal Company
• Annual Report Year: 2004
• Permit Index Doc Type: Hydrology Report
• Media Type: D
• Archive: No

Dennis Jones
Seneca Coal Company
Page 2
September 2, 2005
Mine permit boundary and surrounding azea. The TDS Water Quality Standazds given in Table 4
of Regulation 41 apply to ground water classified as Potentially Usable Quality.
As indicated in the 2004 AHR, twelve out of nineteen groundwater monitoring wells sampled
during 2004 display an increasing trend in TDS concentrations as opposed to ten of nineteen
wells during the 2003 Water Year. TDS concentration increases aze evident in alluvial ground
water in locations along Little Grassy Creek, Grassy Creek, and Bond Creek.
The Division has the following comments regarding water quality monitoring at the Seneca II
mine site and the data and information presented in the 2004 AHR.
As you know, the Division informed our coal-mine operators in a letter dated August 13,
2001 of a significant revision to Rule 4.05.13 regazding establishing ground water points
of compliance. Rule 4.05.13 requires that "One or more points of compliance be
established for any coal mining operation, which in the opinion of the Division, has the
potential to negatively impact the quality of ground water for which quality standazds
have been established by the Water Quality Control Commission." Based on review of
recent Annual Hydrology Reports, it appears that the Seneca II mining operation may
have the potential to negatively impact ground water and therefore the Division believes
that it is necessary at this time to review the current monitoring program to determine the
need for points of compliance. Several important considerations in determining the need
and location for ground water points of compliance have been discussed with you and
other staff members during recent site inspections.
Please review your ground water monitoring program specific to establishing points of
compliance at your site, and provide the Division with your input and feedback. The
Division will work with you during this permit renewal process to identify the need and if
necessary, to determine the specific location(s) for ground water points of compliance.
2. In response to DMG comments from the 2003 AHR, SCC submitted Technical Revision
No. 38 (TR-38) to address changes to the hydrologic monitoring plan. The Division's
comments on the 2003 AHR were adequately addressed through the approved TR-38 and
through minor changes to the current 2004 Water Yeaz report.
3. Table 4 of the 2004 AHR does not reflect the changes to the Ground Water Pazameter
Long List that were approved with TR-38. Please make the appropriate changes to Table
4 and remove the pazameters that are no longer analyzed as a result of TR-38.