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iii iiiiiiiiuiii iu <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />131 3 Sherman St., Room 215 <br />Denver, CO 00203 <br />Phone: (703) 866-3567 <br />FAX: U031 8328106 <br />January 28, 1994 <br />Gary W. Wendt <br />Manager, Environmental Affairs <br />Peabody Western Coal Company <br />1300 South Yale Street <br />Flagstaff, Arizona 86001 <br />RE: Seneca II-W Mine (C-82-057) <br />Technical Revision 21 <br />Dear Mr. Wendt: <br />STATE OF COLORADO <br />OF'~~(O <br />1~_ 4 <br />~~~. b <br />o <br />rel6 ~ <br />Roy Romer <br />Governor <br />M~chacl8 Long <br />Dnision Director <br />We have received and reviewed your responses to our preliminary adequacy review comments <br />regarding TR 21. Most of our concerns were resolved, with PWCC's revised submittal. Comments <br />and questions remaining are summarized below. <br />1. Regarding the "History of Hydrologic Design_", we have not yet fully evaluated PWCC'S <br />response. Since the outcome of this exchange will not directly affect approval of any <br />proposals in TR 21, we believe this matter can be continued after approval of this revision. <br />We do realize that PWCG needs to have this issue resolved in order to complete designs for <br />other operations, and so we are attempting to arrive at a decision in an expeditious fashion. <br />We will transmit our comments, on PWCC's response, to you as soon as possible. <br />2. We find that PWCCs demonstration, that a replacement well for inactive monitoring well <br />GS-S2W-3E[ is not necessary, appears to be reasonable. However, additional information <br />and documentation are required before a final decision can be made. Considerations in favor <br />of PWCC's argument include the following: <br />a) The interburden contains insufficient water to be classified as an aquifer. This <br />conclusion is supported by the fact that the interburden was not mentioned as an <br />aquifer in the Division's Permit Renewal Decision Document and by the geologic <br />characterization of the aquifer. However, early water level data, which could have <br />been used to verify the quantity of water in the interburden, are not available. In <br />addition, the well failed shortly after its installation, and water level data collected <br />thereafter were considered suspect. <br />