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HYDRO23967
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HYDRO23967
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Last modified
8/24/2016 8:44:14 PM
Creation date
11/20/2007 4:14:31 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
Hydrology
Doc Date
11/30/1998
Doc Name
RESPONSE TO COMMENTS ON DRAFT PERMIT COLOWYO COAL CO LP CDPS CO-0045161 FORMERLY COG-850017 MOFFAT C
From
WQCD
To
DMG
Permit Index Doc Type
CORRESPONDENCE
Media Type
D
Archive
No
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Daniel I. Hernandez, Colorado Division of Minerals and Geology <br />Response to Comments on Draft Permit, Colowyo Coal Company, L. P. <br />CDPS No. CO-0045161 (pending). Moffat County <br />Page 5. <br />4. Colowyo requested the change in the chemical description because one chemical is used for dust control, <br />two are used for road deicing and another is used in vehicle cleaning. Thus, these are not used [o directly <br />treat water. <br />5. My recollection from my site visit is [hat this water would gravity-flow from the Washbay pond to the <br />Work Area/Warehouse pond. This is what Colowyo has also stated. Do you concur? <br />6. The referenced section of the rationale is being revised to reflect the new pond dischazge configurations. <br />7. This comment relates to Colowyo's response to the Division's summary of previous permit exceedences as <br />they relate to pond operation. The revised draft permit will summarize discharges from January 1997 <br />through the latest DMR data available. Exceedences prior to [his period that were described in the first <br />draft will not be addressed in the revised draft. Any enforcement action taken by the WQCD related to <br />those earlier exceedences will be determined by the Industrial Compliance Officer. As of this date, no <br />action is anticipated. <br />8. This comment relates to the topic addressed in 7. above. We concur with your comment that Colowyo <br />accepted their general permit certification with the conditions that they have contested. Although facilities <br />covered under general permits cannot adjudicate their certification, Part II.B.15. of that permit informs all <br />permi[tees [hat they may request exclusion from the general permit and coverage under an individual <br />permit. That is what is occurring now, but Colowyo did no[ make this request until it was time to renew <br />their permit. <br />9. As we have informed Colowyo in our response to their comment letters, we are writing their Alternate <br />Limitation Burden of Proof language to be consistent with other coal permits. This is appropriate in light <br />of their conversion of all ponds to automatic dewatering. <br />10. This comment relates to 9. above. <br />11. An "intermittent" discharge is considered by the Division as any discharge that ceases temporarily at any <br />time. A discharge occurring for three days during the first month of a quarter is considered intermittent. <br />All discharges from surface runoff ponds are considered as intermittent. As general information, we <br />verbally instruct permittees with intermittent discharges that are expected to cease before the end of a <br />monitoring period that they should sample when the discharge occurs. A permit[ee who knows that a <br />pattern of intermittent discharge exists but routinely fails to sample when the discharge occurs could be <br />cited for failure to monitor. <br />We do not require samples to be representative of the overall discharge quality, only that the sample is <br />representative of the quality being discharged at [he time of sample. However, if we received information <br />that a permittee as sampling only the best of their discharges to misrepresent the overall quality of their <br />discharge, we would likely reopen their permit to increase the monitoring frequency and make any other <br />necessary changes to require the permittee to collect more representative samples. <br />
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