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January 4, 2013 <br />To: Jared Ebert <br />From: Susan Burgmaier <br />Re: Seneca II -W Mine (Permit No. C- 1982 -057) <br />2011 Annual Hydrology Report <br />Adequacy Review <br />I have completed my review of Seneca Coal Company's 2011 Annual Hydrology Report <br />for the Seneca 11 -W Mine. In general, the report was concise and thoroughly addressed <br />the information requirements of Rule 4.05.13(4)(c) and the approved permit application <br />package. Based on my review, I have the following comments: <br />1. Water monitoring frequency requirements were met at all surface and <br />groundwater monitoring sites. <br />2. Field parameters were collected and laboratory analyses were conducted as <br />required at all groundwater and surface water sites. <br />3. Groundwater Levels: Groundwater levels are generally rising in all of the <br />groundwater monitoring wells except the Wolf Creek Underburden well near <br />Pond 016 (WWCU25). Groundwater levels were particularly high for the 2011 <br />water year due to exceptionally high snowpack and heavy spring precipitation. <br />4. Groundwater Quality: SCC noted and the Division concurs that TDS levels show <br />increasing trends on most of the groundwater wells (coal seam, overburden, and <br />underburden completions) and some values are in excess of values predicted in <br />the Probable Hydrologic Consequences (PHC) section of the permit application <br />package. Overall, reported water quality meets irrigation water standards, with <br />the few excursions noted by SCC for pH, iron, and manganese. <br />Water quality in the shop well (T01 TC in the Twentymile sandstone) meets the <br />domestic use standard with the exception of slightly elevated sulfates. The shop <br />well is not in direct communication with spoil water and the increased sulfates do <br />not appear to be mine related. <br />5. Alluvium: <br />a. TDS in the Hubberson Gulch alluvium is stabilizing and has generally <br />decreased since 2005. <br />b. TDS levels are rising at DCAL -02 in the Dry Creek alluvium, but well <br />below the groundwater point of compliance standard. <br />