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III IIIIIIIIIIIII III ~ ~ <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources oF'CO~ <br /> ~~ <br />f <br />Ne ~ 0 <br />1313 Sherman SI., Room 215 ,r <br />~ <br />~ <br />Denver, CO 80203 . <br />~, <br />Phone: p03) 866-3567 ' revs <br />FAX: (303)832-8106 <br /> Roy Rimer <br /> Governor <br />DATE: December 9, 1992 Michael d. Long <br /> D m¢mn DueUUr <br />TO: Susan Morrison <br />FROM: Stephen WathenG~ <br />RE: Seneca II Mine (C-80-005) <br />1991 Annual Hydrology Report Adequacy Concerns <br />I have had the opportunity to review in detail the 1991 Annual <br />Hydrology Report. The following are my comments: <br />Peabody Coal has done a commendable job of summarizing their <br />surface water hydrology monitoring for the year. I found <br />particularly valuable their summary of exceedances* of stream <br />standards by site for the year, their tracking of total dissolved <br />solids since 1981 and their tracking of trends in milliequivalent <br />for major ions since 1981. <br />In reviewing any annual hydrology report, it is the Division's <br />responsibility to examine the data for that year for exceedances of <br />stream receiving standards or NPDES permit requirements. A listing <br />of exceedances by site for the year, as was done by Peabody, <br />assists us in fulfilling this responsibility.** <br />In reviewing an annual hydrology report, it is also the Division's <br />responsibility to examine the data from that year in relation to <br />historical trends in the data in order to ascertain whether <br />individual parameters are increasing, decreasing or stabilizing <br />over time, as was predicted in the "Probable Hydrologic <br />Consequences" section of the operation's permit. In this vein, <br />Peabody's listing of data since 1981 for both total dissolved <br />solids and milliequivalent for major ions was very helpful. <br />The Division would like to request that Peabody Coal Company <br />consider presenting the data for some additional parameters (for <br />specific sites) in the context of its historical data since 1981. <br />Trends for these parameters appear to indicate significant <br />increases over time or these parameters have displayed repeated <br />high values in the past. Trends for these parameters are not easy <br />to review in the context of a single year's data. In addition, the <br />Division would like Peabody to consider the use of graphs to <br />display this data as graphs are easier to use to interpret trends <br />in the data. <br />