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--= TerraMatr'~x <br />~ ~~&~ <br />1475 Pine Grove Road . PO Box 774018 <br />Steamboat Springs, Colorado 80477 <br />30379.6260 . fax 303-079.9048 <br />December 16, 1993 <br />Mr. Jon Kubic <br />Colorado Department of Health - WQCD <br />4300 Cherry Creek Drive South <br />Denver, Colorado 60222 <br />Re: Kerr Coal Company -Comments on Draft CDPS Permit No. 0043567 <br />Dear Mr. Kubic <br />(via US Mail) <br />I have had opportuni[y [o review the draft individual permit (Permit No. 00456 for Kerr Coal <br />Company (Kerr) providing for discharge of accumulated pit water during the currently ongoing <br />reclamation operations. This new permit will supersede the existing general permit (Permit No. <br />COG850023) for the Kerr operations. Based both on my review and our subsequent phone <br />conversation, I offer the following comments for your consideration and possible modification <br />of the draft permit prior to issuance of the final permit: <br />Efflurnt Limitation for Iron (Fe) -The Fe effluent limitation in the existing permit is <br />3.0 mg/l. It is my understanding that this limitation is based on Federal BAT standards <br />for older discharges. The new effluent limitation (based on water quality standards for <br />the North Platte and Upper Colorado River Basins) of 1.0 mg/1 is considerably more <br />stringent. The new standazd is also applicable under the alternative criteria for <br />stormwater and snowmelt runoff discharge. If relief from the more stringent Fe standard <br />is possible under grandfathering provisions for the older discharge points (ie: 001, 002, <br />003) this revision should be incorporated in the final permit <br />The monitoring frequenry for Fe has been increased to weekly in the new permit from <br />the previous monthly frequency. Based on our conversations, the weekly frequency is <br />generally nandard under new permits and may be appropriate for initial monitoring <br />given the tighter effluent standards. If monitoring ruulu indicate no significant <br />concerns, Kerr may request that monitoring frequency be reduced. <br />Kerr also requests that the permit include provisions for designation and discharge of <br />stormwater only, under the existing effluent standazd; from dischuge points 001, 002, <br />and 003. This request is based on the probability that one or more of the ponds <br />corresponding to these designated discharge points will not be used for pit water storage <br />and discharge and the fact that the ponds will be returned to their prior use as <br />stormwater runoff retention sedimentation ponds following the brief period during <br />which mine water discharge will occur. <br />Certified Operator -Based on conversations with Ms. Sharon Ferdinandson, a certified <br />operator is required for any treatment facility which discharge to State waters. Kerr is <br />pursuing artifidtion options including certifiption of a Kerr employee and wntracting <br />with a certified operator in order to affect wmpliance with this permit provision. Ms. <br />Steamboat Springs, CO.Oenver, CO .Seattle, WA. Juneau, AK • Santiago, Chle SA <br />