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January 4, 2013 <br />To: Jared Ebert <br /> <br />From: Susan Burgmaier 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 for the Seneca II-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 groundwater monitoring sites. <br /> <br />2. Field parameters were collected and laboratory analyses were conducted as <br />required at all groundwater and surface water sites. 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. 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 package. Overall, reported water quality meets irrigation water standards, with the few excursions noted by SCC for pH, iron, and manganese. <br /> <br />Water quality in the shop well (T01TC in the Twentymile sandstone) meets the <br />domestic use standard with the exception of slightly elevated sulfates. The shop well is not in direct communication with spoil water and the increased sulfates do not appear to be mine related. <br /> <br />5. Alluvium: <br />a. TDS in the Hubberson Gulch alluvium is stabilizing and has generally 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 />