HYDRO28884 - Laserfiche WebLink

Home Browse Search

Kimberley A. Wolf. Draft Permit Comments Colowyo Coal Co - Colowyo Coal Mine. CDPS CO-IXM5161 page 2. 6. We will change "pump" to. "transfer". The remainder of this comment ~Jeals with describing the "containment" mode of pond operation that is no longer applicable. Sirn:e it is no longer appropriate, we have revised this section to describe your ponds operating in the "treatment" mode. You will be allowed the opportunity to comment on this wording. This comment dealt with the way the Division described previous exceedences of permit limitations reported on Discharge Monitoring Reports (DMR) for the period from Jtmuary 1995 through June 1997. Because of the time that has elapsed since the original drafr permit went For public comment, that effluent data is no longer the most recent or relevant. Also, the Compliance W ith Terms and Conditions of Previous Permit section of the rationale that accompanied the fast draft was written without the benefit of conversations with the Division staff person who was responsible for reviewing DMR data and deciding appropriate action -the Division Industrial Compliance Assurance Officer (ICAO). That ICAO had resigned from the Division prior to writing of this drafr and prior to the current ICAO coming on board. The second draft will contain a summary of more recent DMR data and the description of Division responses to any exceedences will be written after reviewing information supplied by the current ICAO. (There was no comment 8.) The Burden of Proof Requirements that are the subject of this comment are being revised for consistency for all CDPS permits currently being written for coal mining facilities. We have modified this language to add a bit more explanation of what type of proof the Division seeks for this purpose. Please be aware that while this is our goal, we realize that we cannot completely list all information required since this may vary from site to site and from discharge to discharge. However, it is our intention to require only the data necessary for us to make our determination in each case. We are aware that you have concerns regarding the 48-hour limitation on eligibility for the relief. We believe that this is a reasonable limitation since the relief has always been intended to apply only when a pond is overloaded. Placing a limit at 48 hours is reasonable since we would expect a pond to have recovered from such overloading by that time. And, as I mentioned in a recent telephone conversation, this restriction is universally applied to all coal permittees. To change this for one petmittee would be ' unfair to all others. 10. This change will be made, however please note we are the CWQCD not the WDEQ. 17. The Division applauds your waste minimization activities. The rationale language does not make any specific statements about Colowyo's or any other permittee's specific efforts. Its intention is to encourage waste minimization while stating that the permit will not dictate any requirementsm this area. Petmit 1. Please see response to number 9. preceding. 2. The addition of the word "measurement" will be made. We cannot add the language regarding automatic elimination of WET testing, This is inconsistent with the Division WET Guidance. Our latest information does not indicate that EPA is ready to discontinue WET testing requirements. However, if they did, we could not eliminate WET testing until similar Colorado regulations were changed to reflect this. As you are aware, we have reached agreement concerning internal limits on pit pumped water that will negate the need for WET testing.