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6/10/2013 14:0814:08 <br />Jones, Dennis D. <br />From: Jones, Dennis D. <br />Sent: Wednesday, May 01, 2013 15:59 <br />To: 'Morgan - CDPHE, Kelly'; 'michael.harris @state.co.us' <br />Subject: FW: cdps co- 0048275 potential noncompliance issue <br />Attachments: npdes4 041813.pdf <br />Mike and Kelly, <br />I received from ACZ Labs today (5/1/13) results from our 4/18/13 sample at Outfall 004 for the Peabody Sage Creek <br />Mine (PSCM), CO- 0048275. The lab data indicates that we may potentially be out of compliance of our DMR limit for <br />potentially dissolved (PD) selenium (Se), 4.6 ug /I. The lab data indicates a value of 4.9 ug /I for PD Se. However, the total <br />recoverable (TR) Se value, 4.2 ug /I, is below the DMR limit. We have noticed often that the TR value is less than the PD <br />value, which is just the opposite as one would expect (as the TR digestion is more aggressive than the PD digestion). We <br />suspect that the PD method is subject to matrix interferences that the TR method is not subject to. <br />Attached to this email are the lab results for Outfall 004 (aka, NPDES4). Also in that attachment are the results for Site <br />SSC6, which is the site below the Outfall 004 wetlands that we are considering for a point of compliance for Se. Data for <br />that site are 3.2 ug /I PD Se and 2.4 ug /I TR Se. This indicates that the wetlands site is in compliance for the Se limit. <br />PSCM considers this to be an upset condition, in that 1) we can identify the specific cause of the upset (ie, matrix <br />interference in the PD Se analysis), 2) the facility was being properly operated and maintained, and 3) we submitted <br />proper notice of this upset (ie, this email and phone messages left to both of you). This possible exceedance occurred <br />during spring snowmelt and runoff, similar to the conditions that occurred during the alleged prior selenium <br />exceedances. Due to these climatic and hydrologic factors, the high selenium levels may be contributed by other <br />sources. As you know part of sampling activities is to identify and quantify such sources. In addition, we did get about 2 <br />inches (melted water equivalent) of late, heavy snow in April prior to the sampling event. <br />I left phone messages for both of you today. Kelly replied to my phone call at 2:40 PM today. Along with this email, <br />PSCM considers these to be our CDPS permit required 24 hour notification. The permit requires that we also submit <br />within 5 days a written report. If this email does NOT fulfill that requirement, please let me know, and I will follow up <br />with a mail letter. <br />Thanks you, <br />Dennis Jones <br />Hydrologist. <br />970- 276 -5209 <br />djonesOpeabodyenergy.com <br />Peabodq <br />37796 County Rd. 53 <br />PO Box 670 <br />Hayden, CO 81639 -0670 <br />