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Kimberley A. Wolf. Draft Permit Comments <br />Colowyo Coal Co -Colowyo Coal Mine. CDPS CO-0045161 <br />Page 6. <br />8. (No response required) <br />It is my impression that Mr. Hernandez considers surface runoff ponds at coal mining facilities to be <br />"erosion' control reservoirs". However, I certainly do not speak for him. This may be an important <br />issue to clarify if it means that there are water rights requirements to adhere to. As we responded in <br />our response to Mr. Hernandez's letter, his suggestion to include the language that discharges should <br />adhere to applicable state laws is appropriate and innocuous, especially in light of your comment that <br />Colowyo has been and will continue to be in compliance with all applicable laws and regulations. <br />10. Any proposed changes to the draft individual permit prior to issuance will be offered to you for formal <br />comment during the second public comment period. Additionally, we will strive to keep you informed <br />of substantial changes on an in,`ormal basis prior to the public comment period. <br />11.- 14.(No response required) <br />B. Summary of Rationale <br />1. There remains a difference of opinion between Colowyo and CDMG regarding how the ponds have <br />been designed. The WQCD is not qualified to review the models and make a determination: <br />Regardless, this difference should disappear once the ponds are converted. <br />C. Col~o's September 30. 1997 "Comments on Draft CDPES Permit and Rationale" <br />1. As we have discussed recently, this table will be updated with current information you provided. <br />?. The Division has been persuaded by previous discussions with Colowyo to consider the water that <br />enters the upper mine benches and gravity-flows out to be classified as surface runoff. Based on out <br />understanding of these flows, we believe this is an appropriate classification. The pit pumped water <br />has been extensively discussed in earlier portions of this letter. <br />3. Number 7. on page 5. clarifies the Division_'s method of classifying water as~process water"_and the__ ._ <br />general bases for doing so. <br />4. The subject of this comment will be corrected in the revised drafr. <br />5. The subject of this comment will be corrected in the revised draft. <br />6.-7.(No response required) <br />8. This comment relates to Colowyo's response to the Division's summary of previous permit exceedences <br />as they relate to pond operation. The revised draft permit will summarize discharges from January <br />1997 through the latest DMR data available. Exceedences prior to this period that were described in <br />the first draft will not be addressed in the revised draft. Any enforcement action taken by the WQCD <br />related to those earlier exceedences wilt be determined by the Industrial Compliance Officer. As of <br />this date, no action is anticipated. <br />9.-10.(No response required) <br />