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SPECIFIC COMMENTS Colowyo will now address each comment provided by the CDMG in their January 12, 19971etter to the WQCD: A. Response to Draft CDPS Permit No. CO-0045161 Colowyo has limited data regazding the water quality of dischazges that contain pit pumped water and vehicle wash water. Consequently, the WQCD has made whole effluent toxicity testing (WET) a requirement for these dischazges. In contrast, Colowyo has a 19-year discharge history of meeting the primary effluent standazds from sediment control ponds specifically receiving surface runoff waters from azeas where coal is stockpiled. Thus, there is no rationale to support whole effluent toxicity testing (WET) for these types of outfalls.b This is further supported by the terms and conditions of the existing General Permit No.COG- 850017, which does not provide for WET testing of these discharges. 2. For General Permit No. COG-850017 Colowyo addressed with the CDMG and WQCD on August 4, 1994 and Mazch 22, 1996 condition I.B. i.(d) that excluded manual headgate dischazges from the Altemate Limitations.' The issue was subsequently discussed with the WQCD on September 2, 1997. Following the September 2 meeting with the WQCD it was Colowyo' s understanding that the WQCD was in agreement with Colowyo regazding this issue -that so long as the ponds were designed to contain the 10-yeaz, 24-hour event, manual dischazges as a result of precipitation events to maintain pond capacity would be entitled to the Alternate Limitations. When the ponds become treatment ponds, manual dischazges would no longer be subject to the Altemate Limitations. Please refer to the GENERAL COMMENTS section of this letter for a discussion regazding the present and future operation of Colowyo's sediment control ponds. The CDMG has copies of all of Colowyo's hydrological modeling and the CDMG is encouraged to review each modeling effort. Colowyo would be pleased to review pond hydrology/sedimentology models with the CDMG. Colowyo has already agreed with the WQCD to install devices to measure the 6Letter to K. Sullivan (WQCD) from D. Kennedy, dated Mazch 6, 1996. 'Letter to D. Mathews (CDMG) and R. Shukle (WQCD) from J. Kiger, dated August 4, 1994. Letter to R. Shukle and K. Sullivan, WQCD, from Colowyo' s representative D. Kennedy of Holland & Hart LLP, dated Mazch 22, 1996 and April 3, 1996.