HYDRO21448

• Permit No: C1981019
• IBM Index Class Name: Hydrology
• Doc Date: 8/27/1996
• Doc Name: LIMITATIONS APPLICABLE TO PIT PUMPAGE COLOWYO COAL CO COLOWYO COAL MINE CDPS COG-850017 MOFFAT COUNT
• From: CDOH
• To: COLOWYO COAL CO LP
• Permit Index Doc Type: CORRESPONDENCE
• Media Type: D
• Archive: No

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STATE OF COLORADO
Roy Romer, Governor
Patti Shwayder, Executive Director
L7edicated to protecting and improving the health and environment o/the people of Colorado
4300 Cherry Creek Dr. 5. Laboratory Building
Denver, Colorado 80222-7530 4270 E. 17th Avenue
Phone [phone] Denver, Colorado 80220-3776
[phone]
Watcr Quality Control Division
WQCD-PE-B2
(303)+692-3500 FAX (303)+782-0390
August 23, 1996
James A. Kiger
Sr. Envirotunental Specialist
Colowyo Coal Company LP
5731 State Highway !3
Meeker. CO 81641
RE: Lunitations Applicable to Pit Pumpage
Colowyo Coal Co -Colowyo Coal Mine
CDPS COG850017
Moffat County
Dear Mr. Kiger:
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AUG 2 7 1996
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Colorado Department
of Public Health
and Environment
This letter responds to your verbal question regarding applicable limitations for pit water pumped to
sedimentation ponds and discharged during storm events. We find it more efficient to summarize our position
in writing.
We recall that [his issue has been discussed at length before. Colowyo had stated then that you did not
anticipate a future need to discharge pit water. We assumed this put an end to this issue. However, your
recent question addresses this topic again. So, we want to reinforce our previously stated position. Pit
pumpage is not eligible for alternate effluent limitations. See the Larry Routten, CDMG, April 1, 1996,
letter to Robert Shukle and Roben Shukle's April 17, 1996, letter in response (both copied to Richard
Atkinson). We concluded that alternate limitations do not apply to pit pumpage. EPA has determined that it
should not be necessary to pump pit water during a storm even[, Therefore, we would no[ expect to see an
instance where both sources were combined for discharge. If this did occur, it is the Division's position, that
if pit pumpage is part or all of an effluent stream, then primary limitations would apply to that effluent
stream.
Our immediate concern with Colowyo combining pit pumpage with stornt runoff in a sedimentation pond,
even if the pit pumpage met primary limitations before combination, is that the pond could be upset by the pit
flow and the resulting effluent quality could be significantly degraded. The CDMG has indicated that one of
the ponds that could receive pit pumpage is not sized to accept such pit pumpage. Colowyo has experienced
pond upsets and effluent limitation exceedences in the past due to pit pumpage.
As we have previously stated, it was not our intent to cover pit pumpage within [he general permit for coal
mining facilities under which your facility is certified. This may change when the renewal permit is issued
next year, but for the present, pit pumpage is not an authorized source under this general permit (see Part
I.A.1. of the permit).
If you foresee the need to discharge pit pumpage and/or any other non-surface runoff source in [he future you
should apply for an individual permit as soon as possible. This permit would be "tailored" to your site and
much better suited to changing conditions.