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~• III III III III IIII III STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH Dedicated to protecting and improvingg the health and environment o(the people o(Colorado 4300 Cherry Creck Dr. 5. Laborawry Building Dcnvcr, Colorado 80222-1530 4270 E. 111h Avenue ('hone (703) 692-2000 Denver, Colorado 802 2 0-371 6 (303) 697-4700 January 6, 1994 Wayne R. Erickson Senior Environmental Engineer The Pittsburg & Midway Coal Mining Co. 6400 So. Fiddler's Green Circle P.D. Box 6518 Englewood, CO 80155-6518 RE: Public Notice Comments Pittsburg dr Midway Coal - Edna Mine CDPS No. CO-0032638 Routt County Dear Mr. Erickson: pF' CO~ ti~ f~ Nc . ~ . ~ t B'I6 ~ Roy Romer Co-mmor Palrida A. Nolan, MD, MPH Faentie Director This letter responds to your December 16, 1993, letter regarding the draft renewal permit for the Edna Mine. The term "spoils spring" was first introduced to us by the CO Mined Land Reclamation Division (CMLRD) (now the CO Division of Minerals and Geology - CDMG). This designation has come to be applied generically to springs that, due to disturbances during mining activities, have come into contact with minerals that they would not otherwise come into contact with. This results in a discharge of water of similar quality to mine drainage, lJhile the area around outfall 006 may not strictly be a spoils spring area, the CDMG and the Water Quality Control Division have determined that [he quality of [his water is similar to mine drainage and that this is due to mining activity. Thus, we have determined that this discharge must be regulated through the mine's CDPS permit. Since the CDMG is the entity that classified this discharge as a spoils spring, it is appropriate that you voice your concerns to them. 1'ou may be aware that Susan Burgmaier with the CDMG also commented on the draft renewal permit. (Her letter noted that it was copied to David L. Beverlin with P&M.) Ms. Burgmaier commented that outfalls 002 and 003 contain spoils spring water, and outfall 004 contains mine drainage - all in addition to the surface runoff described in the permit rationale. This information is correlated by the inspection performed September 16, 1991, by Kathy Dolan of our office. The impact of this is that, because the permiC drafter was not aware of these facts, the renewal did not specify limitations that addressed these sources for these three outfalls. We find it necessary to modify the draft to include appropriate limitations and other conditions for these sources. Once the appropriate modifications have been completed, a copy of the revised draft permit will be submitted to you for a short informal comment period.