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MOUNTdIN COdI <br />- COMPdNY~.>~G <br />A Subsidiary of Arcb Western Resources, IZC <br />West Ells Mine <br />POBOx 591 <br />5274 Highway 133 <br />Somerset, CO 81434 <br />(970)929-1015 <br />Fax {970) 929-5595 <br />The results of the 1st quarter 2003 WET test showed that the alkalinity was lower, which resulted in less <br />toxicity to the Daphnia magna and passing of the test. MCC experienced the same successful results <br />with the second quarter 2003 WET test. With the passing of the latest two WET tests, the data have <br />shown a "spontaneous disappeazance of toxicity". Accordingly, it is our understanding that the 4~' quarter <br />2003 WET test failure is closed and that MCC is in compliance with the dischazge permit for outfa11017. <br />Furthermore, it is our understanding that no additional compliance measures related to the failure are <br />required. <br />It is requested the WET test procedure for MCC's dischazge permit (CO-0038776) be modified to reduce <br />the effects of alkalinity. As discussed in the March 7, 2003 letter from WWE and at our meeting on <br />Mazch 12, 2003, the cause of the 4~' quarter 2003 pattern of toxicity was determined to be high alkalinity. <br />High alkalinity is acting as a confounding factor in the tests and is preventing the test from measuring <br />other causes of toxicity. Therefore MCC requests the WET test procedure be modified by adjusting the <br />alkalinity of the test water to less than 1000 mg/L, which is the estimated no effects concentration of <br />alkalinity as determined using the STR model and verified with WET test data (i.e., Figure 1 in WWE <br />letter). If a WET test fails at an effluent allcalinity of less than 1000 mg/L, then the test would be <br />considered to have failed in terms of permit compliance. If a test fails at an alkalinity of greater than this <br />value, the test will be re-analyzed with alkalinity adjusted to 1000 mg/L. <br />We request your written response to confirm that: 1) the 4`1i quarter 2003 WET test failure is resolved, <br />and 2) the WET test procedure should be modified as described above. If you have questions or need <br />additional information concerning these requests, please contact me at (970) 929-2238. <br />Sin ly, 1~ <br />~' +~-~_ <br />enry azbe <br />Environmental Engineer <br />Enclosures: January 2003, CT&E, NPDES Biomonitoring, West Fork of Sylvester Gulch, Discharge <br />Point 017; Apri12003, Results of an Acute Biomonitoring Test Performed for Mountain Coal Company, <br />SeaCrest Group; Memo from Wright Water Engineers to MCC Apri121, 2003, Recommended Level of <br />Alkalinity Adjustment for Wet Tests. <br />cc: Mr. Bab McConnell -WQCD, CDOPH&E <br />Mr. Chris Gates -WQCD, CDOPH&E <br />James Burnell - CDMG-OMLR <br />P. Schmidt <br />D. Mehan -Wright Water Engineers <br />