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potential to release water under certain circumstance where the effluent may not meet <br />discharge standards. For example, it is possible that a noncompliance discharge could occur <br />over a weekend and a sample never obtained. Our system is superior because we can <br />control the discharge to better avoid a potential noncompliance situation. <br />3- Issue #2-b <br />The design and operation of the East Taylor Pond does not include a "permanent <br />pool" of water, <br />The Division has proposed that Colowyo consider modifying the way that water in <br />the East Taylor Pond for any of our sedimentation ponds for that matter) is managed. In <br />particular, the Division has proposed that by either perforating or lowering the riser pipe we <br />could change the pond's status from a pond that utilizes containment to control the design <br />event to a pond that utilizes treatment to control the design event. The idea has some merit <br />for ponds receiving must of their runoff from reclaimed, well-vegetated areas containing <br />little suspended solids. The downside of the Division's proposal is that, as we noted in the <br />previous section, with an automatic discharge system there is no guarantee that the effluent <br />will meet the discharge standards. We could potentially lose some degree of control over <br />the quality of effluent discharges resulting in Violations. <br />Colowyo will certainly give the Division's proposal some careful consideration. <br />Should we elect to adopt this alternative pond management strategy, the appropriate <br />revision will be submitted to the Division. <br />4- Issue #3 <br />The Division requested an estimate of quantity of water to be pumped into the <br />sediment pond at any given time and whether the ponds can handle the flows. <br />Based upon our 19 years of experience in the East pit, since there is virtually no <br />ground water, the small amount of water in the pit is a function of surface runoff from <br />precipitation. This volume would, of course, be difficult to predict. Furthermore, since we <br />are mining updip, what little water collects from precipitation generally dissipates downdip <br />away from mining into the spoil. The west pit, being in the developmental box cut stage, <br />presently has no spoil areas until possibly sometime in 1997. Therefore, water may or <br />may not develop and if it did depending on the circumstances, it may or may not have to be <br />pumped. <br />Jf we were to pump, and L we pumped all day long, we might expect .2 to .3 ac/ft <br />of water to enter the pond. This volume of water is so small that it would simply be very <br />similar to water entering the pond from a routine, small storm event or snowmelt and easily <br />handled by the pond. We would simply continue to manage the pond as we do with any <br />small inflow, by opening the headgate and dewatering. The risk is ours to insure that the <br />water meets applicable discharge standards. <br />Furthermore, as we demonstrated by the remodeling of the West Pit Pond (the TR- <br />35 that we subsequently withdrew) once apit/reclamation scenario replaces the worst case <br />2 <br />