HYDRO29243

• Permit No: C1981071
• IBM Index Class Name: Hydrology
• Doc Date: 11/12/1985
• Doc Name: CDPS PN CO-0027154
• From: COLO YAMPA COAL CO
• To: WQCD
• Permit Index Doc Type: NPDES
• Media Type: D
• Archive: No

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Colorado Yampa Coal Company
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29588 Routt County Road #27. Oak Creek, CO 80467 • [phone]
Hand Delivered November 14, 1985
November 12, 1985
Mr. Robert ~. Shukle
Industrial Unit Chief
Permits and Enforcement Section
Water Quality Control Division
Colorado Department of Health
1313 Sherman Street
Denver, Colorado 80203
Re: CDPS Permit No. CO-0027154
Dear Mr. Shukle:
Colorado Yampa Coal Company (CYCC) is authorized to discharge into state
waters under CDPS Permit CO-0027154. Data collected by CYCC indicates that
effluent limitations have been exceeded at various times and discharge points
during the time period March, 1984 to September, 1985. Enforcement action is
pending for these alleged exceedances and the amount of a fine has not been
determined.
CYCC wishes to address the issue of total recoverable stream standards
versus total effluent limitations. In a October 24, 1985 letter to the CDOH,
CYCC submitted its Amended Petition for a Change in Water Quality Standards
and stated that we would correspond with the Permits and Enforcement Section
on the total versus total recoverable problem. The purpose of this letter is
to honor that commitment and to request that the Permits and Enforcement Sec-
tion consider the following mitigating factor in assessing the extent of non-
compliance with regard to alleged water quality exceedances.
Stream water quality standards applicable in the receiving waters at
CYCC's CDPS discharge points are in terms of total recoverable concentrations
for metals. However, effluent limitations in Permit CO-0027154 are in terms
of total concentrations for metals. Different chemical analyses are used to
determine total and total recoverable concentrations; they are not equivalent
measures. For any parameter, the total value is generally greater than the
total recoverable value. The numerical value of total metal limitations is
based on total recoverable stream standards for most metals. This amounts to
an apples and oranges comparison. CYCC believes that a true evaluation of
environmental damage resulting from its effluent discharge must be in the same
terms as the stream standards. Elevated total metal concentrations do not
necessarily indicate a violation of total recoverable standards, as evidenced
by the following data.
CYCC has collected 38 water samples which have been analyzed for both
total and total recoverable zinc, copper, silver and iron. This data was used
to establish a mathematical relationship between total and total recoverable