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<br />~II ~~~~I~~I~~~~~ ~I~ <br />sss <br />Mountain Coal Company <br />West Elk Mine <br />Post OKce Box 597 <br />Somerset, Colorado 81434 <br />Telephone 970929.5075 <br />Fax 970 929-5595 <br />March 28, 1997 <br />RECEIVED <br />APR 0 21991 <br />Division of Mmerels & Geology <br />Mr. Jon C. Kubic, Environmental Protection Specialist <br />Permits and Enforcement Section <br />Colorado Department of Public Health and Environment <br />Water Quality Control Division (WQCD) <br />4300 Cherry Creek Drive South <br />Denver. CO 80222-1530 <br />`~ <br />Re: Mountain Coal Company, West Elk Mine, CDPS Permit No. CO-0038776, Response <br />Letter for Outfalls 013 and 015 <br />Deaz Mr. Kubic: <br />Mountain Coal Company (MCC) provides the following responses to the issues regarding the <br />above-mentioned Outfalls (discharge points) per your letter of March 11, 1997. <br />The amendment applications for Outfalls 013 and Outfall 015 were submitted to the Water <br />Quality Control Division (WQCD) in letters dated November of 1996. At that time, MCC <br />estimated that a discharge of 0-750 gpm would be conveyed to the North Fork of the Gunnison <br />River (North Fork) via Outfa11013. As the WQCD is awaze, since the date of application five <br />months ago, an unprecedented mine inflow event occurred that changed some of the original <br />engineering calculations. As stated in your letter, the WQCD erroneously used a maximum <br />effluent flow (50 gpm) for its calculation, rather than utilize the 750 GPM figure from MCC's <br />original application. MCC has since redesigned the pipeline to discharge a maximum of 2,000 gpm <br />directly into Lone Pine Gulch (and then to the North Fork). The pipeline has not been <br />constructed as this facility has not yet been approved by the Colorado Division of Minerals and <br />Geology (CDMG). <br />The sampling and analysis requested by you in paragraph 3 of the March 11, 1997, letter, is being <br />conducted on the North Fork and the mine water. The existing solute chemistry record for the <br />North Fork and the mine water shows that none of the parameters requested by the WQCD and <br />CDMG are problematic. This is because there is neither acid mine drainage (pH<6) nor an alkaline <br />mine dischazge (pH>9) at MCC and "heavy metals" have not been a problem in the past at the <br />West Elk Mine, nor are they expected. The solute chemistry information and the analyses the <br />WQCD requested will be provided upon completion of the pipeline construction. <br />The Division is already in receipt of instream Whole Effluent Toxicity (WET) test analyses for the <br />North Fork both upstream and downstream of MCC's operations. The WQCD received this <br />