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Dennis Jones <br />Seneca Coal Company <br />Page 2 <br />Mazch 26, 2004 <br />Consistent with PHC predictions, TDS trends are increasing at all NPDES and downstream <br />surface water sites. However, no TDS predictions were exceeded in 2003 for samples collected <br />from the major surface water outfalls including Grassy Creek, Armand Draw, and Sage Creek. In <br />all cases, the average TDS concentration was below the predicted TDS value for these sample <br />sites. There were no excursions of NPDES effluent limits during the 2003 water Yeaz. <br />The Division has the following specific comments regazding the collection and reporting of <br />surface water and ground water monitoring data contained in the 2003 AHR. <br />1. In response to DMG comments from the 2002 AHR review, SCC will submit a revision <br />in 2004 to add Spoil Spring YSSPGl to the approved monitoring program contained in the <br />permit document. This spring was first discovered in September 2002. When this revision is <br />submitted, please also update Table 15-9 to include a footnote indicating what the semiannual <br />water quality analyses will consist of. Table 15-9 currently indicates discharge and water quality <br />frequencies for springs. <br />2. Table 6 of the AHR shows exceedences of Ground Water Agricultural Use Standards for <br />cadmium and lead. Likewise Table 13 shows exceedences of Surface Water Quality Standazds <br />for chromium. When in fact, the detection limits were elevated by the laboratory for these <br />constituents and the samples were actually non-detect for cadmium and lead on Table 6 and <br />chromium on Table 13. It would be preferable to not list these as exceedences. The Division <br />concurs with providing and explanation of the elevated detection limits in the text portion of the <br />AHR when they occur. SCC should continue to work with the laboratory to achieve lower <br />detection limits that are less than or equal to the CDOH standazds for these constituents. <br />If you have any questions concerning the Division's review of the 2003 AHR, please contact me. <br />Sincerely, <br />M, ~ P ~~ <br />Michael P. Boulay <br />Environmental Protection Specialist <br />C: Sandy Brown <br />