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iii -ii~iiiiiiiii-ii STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources I J 13 Sherman SL, Room 215 Denver, Colorado 80203 Phone (3031866-3557 FAX' 1303) H32-8105 November 7, 2000 Ms. Susan Nach[rieb Colorado Department of Public Health and Environment Water Quality Control Division 4300 Cherry Creek Drive South Denver, CO 80222-1530 DIVISION OF MINERALS GEOLOGY R EC lAMA710N MIN ING•SA FE7Y Bill Owen Governor Greq E Walther E.ecmive Director n~~chael B. Long Drvisio~ Duector RE: CPDS permit renewal NO. CO-00271 ~4 Dear Ms. Nachtrieb: The Division has reviewed the draft copy of the "Rationale for Public Notice" for CPDS permit number CO- 0027154. The Rationale states that the permit applies to Mine 1, 2, and 3 South and the Eckman Park Mine. Page two of the rationale states that one of the sources of wastewater is "mine drainage pumped from the underground mine". It is not clear that the source of the underground mine water discharge is from the Foidel Creek Mine. The Division believes the discharge permit should clearly and concisely indicate authorization to discharge from the Foidel Creek Mine. Many of the sediment ponds were originally permitted under the Colorado Division of Minerals and Geology permit for the Mine No. ]and 2, and Eckman Park Mines (C-81-07 ] ). With the reclamation of surface mining of ivtines No. 1 and 2, and Eckman Park Mine, the active operations continued underground in the Foidel Creek Mine (C-82-056). Since the active facilities areas were transferred to the Foidel Creek Mine, many of the sediment ponds were transferred to the Foidel Creek Permit as well. CPDS Outfalls 003, 005, 007, 002, 004, 006, and 008 receive runoff from areas affected by the active Foidel Creek Mine operation. Outfall 020 is currently pumped to the main Foidel Creek Facilities area where it is discharged into an unreclaimed surface mining pit, and eventually discharges through outfall 005. It is not clear when reviewing the page titled "Authorization to Discharge under the Colorado Discharge Permit System" that CPDS Permit No. CO-0027154 applies to portions of [he Foidel Creek Mine. One of the Division of Minerals and Geology's concerns regarding clarification of this relationship with this CPDS permit renewal, stems from the potential for Colorado Yampa Coal Company to apply for final reclamation bond release prior to the next permit renewal. Additionally, the CPDS permit renewal for CO-0027154 does not make it clear that the Stormwater Management Plan described on pages 14 through 19 applies to the Foidel Creek Mine as well as Mines No. 1, 2, 3 South, and Eckman Park. Clarification that the underground mine water discharge source is the Foidel Creek mine, the SWMP applies to the Foidel Creek Mine, and the CPDS permit CO-0027154 applies to the Foidel Creek Mine in addition to Mines I, 2, 3South, and Eckman Park would address the Division's concerns. If you have any questions regarding this letter, please call me. Sincerely, u Janet . Binns Enviro mental Protection Specialist C:/j hb/C82056/dmrs/000027 l 54.doc cc: Dan Hernandez, Kent Gorham, DMG