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iii iiiiiiiiiiiii iii <br />DECEIVED <br />~~.~~ IVOV 0 9 1998 <br />S ~VE~ ~ , „~n u~ Minerals & GeorogY <br />Coal Company Seneca Coal Company <br />Mr. Mike Boulay <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203-2273 <br />November 4, 1998 <br />RE: NPDES Monitoring Frequencies for the Seneca II, Seneca II-W, and Yoast Mines <br />Colorado Discharge Permit CO-000221 <br />Dear Mr. Boulay, <br />After our conversation during last month's inspection, in regards <br />to monitoring frequencies at sediment ponds, I decided to <br />investigate the possibility of getting those frequencies reduced <br />from weekly to monthly. Seneca Coal Company (SCC) currently <br />monitors, at the three above-mentioned mines, the following <br />parameters: <br />pH <br />flow <br />oil/grease (visual) <br />(Points 004, 005, 008, 009, and <br />these three parameters November to <br />suspended/settleable solids <br />total iron <br />total dissolved solids <br />whole effluent toxicity <br />weekly <br />weekly <br />weekly <br />011 are monitored <br />February) <br />monthly <br />monthly <br />monthly for <br />quarterly (optional), <br />performed monthly <br />quarterly - annually, <br />depending on the site <br />I talked to the Colorado Department of Health (CDOH) about these <br />monitoring frequencies. It turns out that there is no federal or <br />state regulation requiring weekly monitoring. The CDOH stated <br />that they might consider a reduction in monitoring, especially if <br />I got concurrence with your Division. <br />Due to the mountainous terrain in the Seneca area, and the four- <br />wheel drives roads that are the only access to many of these <br />sites, performing weekly monitoring (especially during bad <br />weather and during the winter) is costly to our company and can <br />be very difficult and sometimes dangerous. Just last April, I <br />had an all-terrain vehicle roll over on me, cracking several ribs <br />Seneca Coal Company P.O. Drawer D Hayden, Colorado 61639 <br />Telephone (970) 276-3707 FAX (970) 276-3014 <br />