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- ~ III IIIIIIIIIIIIIIII ~ <br />STATE OF COLORADO <br />Roy Romer, Govei <br />DEPARTMENT OFNATURALRESOURCES <br />MINED LAND RECLAMATION DIVISION <br />DAVID C. SNELTON, Dlreetor <br />August 28, 1987 <br />Mr. Jim Lunan <br />Peabody Coal Company <br />1300 South Yale <br />Flagstaff, Arizona 86001 <br />Re: Seneca II 1986 Annual Hydrologic Report - File No. C-80-005 <br />Oear Mr. Lunan: <br />The Division has reviewed the 1986 Annual Hydrologic Report (AHR) compiled <br />from hydrologic data collected at the Seneca II Mine. Peabody Coal Company <br />Hydrologists are to be commended for the quality of the report. <br />The Division review of the AHR indicates that Peabody Coal Company is <br />requesting three revisions to the approved permit document. As these <br />revisions include requests to reduce monitoring frequencies, a technical <br />revision should be submitted to the Division. This revision should describe <br />and justify the requests for monitoring reduction, and include the appropriate <br />revised pages for the permit document. <br />A brief comment regarding each revision topic follows: <br />1) Peabody Coal Company has requested that the monthly monitoring of <br />Wells GW-S31-A2 and GW-S33 by reduced to semi-annual monitoring of field <br />parameters and sampling for water quality. Given the water quality <br />correlations with NPDES 002 and Site SW-S2-2, this request appears <br />reasonable. <br />2) A discussion is provided pertaining to the Peabody commitment to verify <br />the HYMO Model (Appendix G). An explanation is offered that the <br />comparison is not feasible due to limitations of the model. A request is <br />made (P. G-1) to revise the permit text to remove this commitment. <br />The Sedimot II model is currently being used by Peabody for drainage <br />design. In considering the proposed revision, the option of verifying <br />the Sedimot II model should be reviewed by Peabody based on the intended <br />purposes of the commitment. This consideration should be made prior to <br />the revision submittal. <br />3) A request is made by Peabody (P. G-7) to modify the previous commitment <br />for annual surveys of sediment level in the sediment ponds. This <br />commitment was made at the time of abatement of Notice of Violation <br />No. C-85-081. The request is to reduce the frequency of surveys to every <br />five years for Ponds 002 and 003 and every two years for Pond 004. <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567 <br />