HYDRO22593

• Permit No: C1980007
• IBM Index Class Name: Hydrology
• Doc Date: 7/14/2004
• Doc Name: Request for Variance of DMRs
• From: Mountain Coal Company
• To: WQCD
• Permit Index Doc Type: DMR’s
• Media Type: D
• Archive: No

MOUNTAIN COAL
COMPANYL.L.c.
A Subsidiary of Arch Wes[em Resources, LLC
July 9, 2004
RECE~ ~~E
IJUL 1; =~~'~ RECEIVED
Divishll~f Miner~[~ and "-~--•.
JUL 142004
West Elk Mine
POBox 591
5174 Highway 133
Somerset, CO 81434
[phone]
Fax [phone]
Mr. Christopher L. Gates Division of Minerals and Geology
Colorado Department of Public Health and the Environment
Water Quality Control Division
4300 Cherry Creek Drive South
Denver, CO 80222-1530- - -- - ~ - - - - -
Re: Mountain Coal Company, LLC, (MCC), West Elk Mine, CDPS Permit No. CO-0038776,
Request for Variance of Discharge Monitoring Reporting.
Deaz Mr. Gates:
Referencing the Division's Renewal of CDPS Permit CO-0038776, issued April 19, 2004, and effective
June 1, 2004, for the West Elk Mine, Mountain Coal Company, hereby respectfully requests a variance in
dischazge monitoring reporting. Specifically, MCC is requesting a variance from the monthly report
requirement of Discharge Monitoring Reports at VI, C. Reporting, 1., Discharge Monitoring Report: of
the Summary of Rationale, page 10, for Permit No. CO-0038776.
MCC proposes to submit Quarterly Discharge Monitoring Reports (DMRs) as we have done for over 22
yeazs at the West Ells Mine. The request is necessary and prudent as the sediment pond dischazges aze
sporadic depending on snowmelt and rains. The exception to this is the continuing dischazge of water
from Outfa11017 for the mine dewatering.
Currently, MCC reports quarterly for 13 Outfalls (dischazge points) which report "No Dischazge", unless
there is significant precipitation or wash-down events. The DMRs generated by MCC require a
significant time to prepaze, and also require an officer of the company sign his name 33 times. The
monthly reports as required in the permit renewal would require 396 signatures annually.
Furthermore, when a dischazge occurs, MCC sends the discharge samples to the laboratory for analyses
and the reports aze generated and reported to MCC in a range from 10 days to four weeks after the
sampling date. If monthly discharge monitoring reports are required, the reports will be deficient of the
quality reporting by three weeks or more. This means the reports would be one month late due to the
laboratory processing time.
MCC is not requesting a waiver of dischazge monitoring reporting, but rather, a variance to continue
quarterly discharge monitoring reporting as we have in the past. Please let me know at your eazliest
convenience if the Division approves of this variance request.