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t III IIIIIIIIIIIII III <br />STATE OF COLUR~uU <br />Roy Romer, Governor <br />Patti Shwayder, Fxecutive Director <br />Dedicated to protecting and improving (he health and environment olthe people o(Colorado <br />4300 Cherry Creek Dr. S. Laboratory and Radiation Services Division <br />Denver, Colorado 80246-1530 8100 Lowry Blvd. <br />Phone (303) 6922000 Denver CO 80210-6928 <br />Located in Glendale, Colorado (303) 692-3090 <br />h upahvww.cdphe.-'tale. co. us <br />Water Quality Control Division <br />WQCD-PERMITS-B2 <br />(303) 692-3500 FAX (303) 782 0390 <br />February 20, 1998 <br />Daniel I. Hernandez <br />Senior Environmental Protection Specialist <br />Colorado Division of (\4nerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver. CO 80203 <br />RE: Response to Comments on Draft Permit <br />Colowyo Coal Company, L.P. <br />CDPS No. CO-0045161 (pending) <br />Moffat Cotmty <br />Dear Mr. Hernandez: <br />RECEIVED <br />.- n r q <br />i ._. r. J r.~ 1 <br />Division of Minerals & Geology <br />pF Cpl <br />~/ <br />v <br />a <br />r~~ <br />~ r8'I6 ~ <br />Colorado Depanmenr <br />oFPublic Health <br />and Environment <br />This letter responds at your request to the specific questions raised in your January 12, 1998, letter. Our <br />responses will reference the numbering used in your letter. Since some comments are not in the form of <br />questions seeking answers, our numbering will not be sequential. <br />A. Permit <br />4. You are correct [o assume [hat neither vehicle wash water nor pit pumpage should be discharged through <br />any outfalls other than 002, 004, 007, 008, 009 and OIO. Further, the additional label "b" is added to <br />these outfalls to denote that the discharge is expected to contain one or both of these sources. Table II-1 in <br />the draft rationale specifies which sources are authorized from each outfall. You are also correct that <br />discharges from these outfalls that are composed mostly of vehicle wash water or pit pumpage are never <br />eligible for relief from primary limitations. The permittee will be provided with separate discharge <br />monitoring reports that will be denoted with the "b" label to indicate they must meet [he limitations in Part <br />I.A.I.b. of the permit. <br />As currently proposed in the draft permit, in your example this discharge would be eligible for exemption <br />from primary limitations through 48 hours after the event ended and the exemptible parameters would be <br />TSS and total iron. After 48 hours, all discharges would have to meet the primary limitations. Colowyo <br />has mentioned the discrepancy between the applicable periods for application of alternate limitations for <br />rainfall vs. snowmelt; i.e., for rainfall the "clock" begins when measurable precipitation ends and for <br />snowmelt the "clock" begins when inflow to the pond stops. We are currently examining the origin of this <br />particular language to determine the basis and whether it is inconsistent. <br />