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- - • ~=- II I I II I II I II IIII III <br />999 <br />The Pittsburg 8~ Midway Coal Mining Co. <br />M AChevronCompany <br />P~i' +• 6400 Sa.M Fiddler's Green Circle. Englewood, CO 80111 ~ Phone (303) 9303600 <br />RFCFIVEG <br />October I5, 1997 OCT 1 ~ 1997 <br />CDPS Permit CO-00326~~sion of [vuneraG 6 GeClogy <br />Mr. Jon C. Kubic <br />Colorado Department of Public Health and Environment <br />WQCD-PE-B2 <br />4300 Chem Creek Drive South <br />Denver, CO 80222-1530 <br />Dear Mr. Kubic: <br />In accordance with part I.B.3.e of the above referenced permit, P&M hereby requests relief from <br />further investigation and testing of the WET testing protocol at Dischazge Point 007. P&M <br />believes that sufficient materials have been submitted to the agency the establish the following: <br />(1) P&M has complied with the terms and conditions of the permit compliance schedule for <br />the PTI/TIE investigation. P&M submitted a formal TIE, dated Mazch 1997, under cover <br />letter dated Apri124, 1997. The results of the TIE indicated that the probable cause of the <br />"Pattern of Toxicity" was related to TDS concentrations in the effluent. <br />(2) During the period of~the toxicity incident, Dischazge Point 007 has been in compliance <br />with all of the other permit conditions. This statement is based on the sampling data <br />reported to the Division for the first four months of 1997. <br />(3) During the period of the toxicity incident, P&M has properly maintained and operated all <br />facilities and systems of treatment and control. The mines treatment systems consist of <br />settling ponds upstream of Dischazge Point 007 which aze self-regulating in terms of <br />runoff discharge. The ponds are visited on a weekly basis and fully inspected on a <br />quarterly basis for functional integrity. <br />(4) Despite the circumstances described in pazagraphs (1) and (3) above the source and the cause <br />of the toxicity cannot be resolved in an economically feasible fashion. P&M has provided <br />the Division and the Colorado Water Quality Control Commission with an estimation of the <br />of the cost to construct and operate areverse-osmosis treatment plant to remove sulfate <br />which is the major component of TDS in the Edna Mine effluent. The cost estimation was <br />provided in the document entitled, "PETITION OF THE PITTSBURG & MIDWAY COAL <br />MINING CO. FOR REVIEW AND REVISION OF THE DOMESTIC WATER SUPPLY <br />