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__~.. <br />Peabody <br />Twentymile Coal Company <br />29515 Routt County Road X27 <br />Oak Crsek, CO 80467 <br />970.879.3800 <br />April 28, 2006 <br />Ms. Tanya Watson <br />Colorado Department of Public Health and Environment <br />Water Quality Control Division -Permits and Enforcement <br />4300 Cherry Creek Drive South <br />Denver. CO 80222-1530 <br />RECEIVED <br />MAY ~ 4 2006 <br />Division of Minerals & Geology <br />RE: PERMIT CO-0042161: 4TH QUARTER 2005 DMR SUBMITTAL <br />Dear Ms. Watson: <br />Please find enclosed the above referenced discharge monitoring reports for the period <br />from January 1, 2006 through March 31, 2006, for Outfalls OO1A (site 115), 002A (300E), <br />and 3001. Outfall 001A did not discharge during the period. Attached are blank DMRs <br />for this Outfall with the No Discharge box checked. <br />Wastewater Outtalls 002A and 3001 flowed each week of the period. Permit <br />exceedances were noted, for 002A (Site 300E waste water effluent). A recent issue has <br />been achieving an over 85 % BOD removal for 002A. This periods monthly low average <br />(March) achieved 75%. Our quarterly average was somewhat higher at 80%. In a <br />January 2006 telephone conversation with Mr. Clyde Sharp, we discussed that influent <br />flow to the waste water treatment system includes significant greywater flow dilution (i.e. <br />boot cleaning, showers, sinks, floor drains, etc.). Influent BOD and TSS are often <br />relatively low to start with, thus, it is difficult to meet the minimum BOD % removal <br />limitation. Mr. Sharp recommended we seek a permit modification for the 85 % removal <br />limit. As he suggested, we contacted Mr, Andrew Newhart of CDPHE (303-692-3655) <br />regarding this issue, and submitted a January 31, 2006 letter describing the situation <br />along with a request for an amendment to the permit (see attached). His review is still <br />pending. Please note that treated wastewater from 002A is not discharged into any <br />surface streams. It is discharged back into an abandoned portion of the underground <br />mine, where it is diluted by groundwater. There are no potable wells within this area, so <br />treated discharge remains isolated underground. Thus, in our opinion this situation does <br />not constitute a health issue to Twentymile employees or the public. <br />Also note that last fall we hired Mr. Dick Bowman, a former head of the Grand Junction <br />CDPHE, to trouble shoot our system. He conducted an initial evaluation. Now that the <br />snows are gone, we will be working with him further this year, to resolve these issues. <br />