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SENECi4 <br />Coal Company Seneca Coal Company <br />July 24, 2013 <br />Colorado Department of Health <br />WQCD -PE -B2 <br />4300 Cherry Creek Drive South <br />Denver, CO 80246 -1530 <br />RECEIVED <br />JUL 3 0 2013 <br />Q�ivis ring & safety <br />ion, <br />RE: Quarterly Discharge Monitoring Report for Seneca Coal Company, Permit CO- 0000221 <br />Dear Sir or Madam: <br />Pursuant to the quarterly reporting requirements contained in Colorado Discharge Permit CO- 0000221 for <br />the Seneca Mine Complex, enclosed find the second quarter 2013 discharge monitoring reports for <br />Outfalls 005, 006 and 008 to 017. In this quarter, intermittent discharges were observed at Outfalls 005, <br />011, 013 and 014. No flows were observed at Outfall 009. All other Outfalls discharged continuously. <br />Three excursions of DMR limits occurred this quarter. The first involved the total recoverable iron value <br />of a sample from Outfall 011 taken on April 29. The second involved the total recoverable iron value of a <br />sample from Outfall 016 taken on April 30. The third involved the pH value of a sample from Outfall 013 <br />taken on May 2. Attached to this cover letter are emails which discuss the details of each excursion. These <br />emails also served as our five day notice to the WQCD. Also attached are lab data referenced in the <br />emails. <br />In addition to these excursions, one selenium (Se) value reported by Seneca's lab (ACZ Labs in <br />Steamboat Springs, CO) was not reported on the DMR. This occurred on a sample collected at Outfall 008 <br />on June 10, 2013. Additional analyses for selenium were performed by the lab as described below. <br />The original potentially dissolved (PD) by ICP -MS selenium analysis was performed on June 13, and <br />yielded a value of 7.1 ug/L. The lab also performed a total recoverable (TR) selenium analysis on the <br />same sample on June 12 that resulted in a value of 1.4 ug/L. Suspecting that water matrix interference <br />caused the high PD selenium value compared to the TR selenium value, the lab performed an additional <br />digestion on the PD sample on June 21 to remove the water matrix interference. The result of the June 21 <br />analysis on the PD selenium sample was 1.2 ug/L. <br />The value reported on this DMR for Outfall 008 was 6.6 ug/L, which was the highest of the three reliable <br />monthly PD Se ICP -MS values for this quarter (6.1, 6.6 and 1.2 ug/L, respectively). Seneca believes the <br />7.1 ug/L value noted above to be a false high value, based on the total recoverable Se analyses performed <br />on that sample. As one would expect the total recoverable method to result in the same, or higher, value <br />than the potentially dissolved method (the former involves a hot acid digestion, while the later involves a <br />cold acid digestion), we suspect that the 7.1 ug/L value to be in error. This may be due to matrix <br />interference in the sample that displays itself in the potentially dissolved ICP -MS method. An additional <br />TR digestion apparently removes that interference. <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276 -5209 • FAX (970) 276 -5222 <br />