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Daniel 1. Hernandez, Colorado Division of Minerals and Geology <br />Response to Comments on Drafr Permit, Colowyo Coal Company, L. P. <br />CDPS No. CO-004516I (pending). Moffat County <br />Page 6. <br />FEBRUARY 27. 1998 LETTER <br />A. Draft CDPS Permit No. CO-0045161 <br />1. Please see response number 1. on page l . of this letter. <br />2. We believe [hat the subject of this comment is moot since it relates to the old pond configuration. As <br />we stated in number 6. on page 2. of this letter, Colowyo has acknowledged that all future manual <br />discharges will have to meet primary limitations. <br />3.-4. (No response requested) <br />There may be some confusion. The "clock" itself is activates at the end of the rainfall. We refer to the <br />clock not as the entire period related to precipitation but only the end portion of it. We apply the <br />period of exemption for rainfall as beginning when rainfall commences and ending 48 hours after <br />rainfall stops. The "clock", in effect, counts down from the end of the rainfall to a time 48 hours in the <br />future. For snowmelt, all of this applies except the "clock" begins counting down when snowmelt <br />ceases entering [he pond and ends 48 hours in the future. We have not expected the beginning point to <br />be controversial, only the ending point. But, we welcome the opportunity to offer this clarification. <br />To address potential situations at Colowyo, we intend to offer the opportunity for them to demonstrate <br />that for a specific event, the exemption period was unfairly shortened due to long travel time from the <br />point of rainfall to the pond. <br />6. This concern should go away with the change over from manual to automatic dewatering. <br />7. (No response requested to first part) <br />[s a permittee typically required (or expected) to design size a pond to treat the design flow of pit <br />pumped water or vehicle wash water plus the ]0-year, 24-hour event? We have seen this at other sites <br />(at least the inference was made that the ponds were designed this way). We see your problem with <br />site inspections relative to these sources. We hesitate [o require continuous flow recorders due to cost <br />and level of maintenance, although we are not by any means opposed to them. We have received a lot <br />of resistance from other permi[tees (primarily domestic permittees) to installing such devices. As an <br />alternative, would you find it acceptable if the permittee were required to choose a measuring device <br />that is accurate within 10% (the WQCD standard) and maintain a log for review on request? This <br />would leave it open to creativity. For pumping, we have accepted pump curves as adequate measuring <br />devices. Of course, the operator would have to record the periods pumping occurred also. We are <br />open to other workable suggestions. <br />8. This concern should go away with the change over from manual to automatic dewatering. <br />9. We are adding your suggested wording. We feel it is up to the permittee to determine if other laws <br />apply than those of which they are aware. <br />10. (Please see no. 10 on page 3. of this letter.) <br />