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iiiiiiiiiiiiiiiiiii ~~ The Pittsburg ~ Midway Coal Mining Co. A Chevron Company 6400 South Fddler's Green Q'rcle, Englewood, W 80nt • Phone (303 9304116 Mail Address: P.O. Bmc 8518, Englewood, CO 80155&518 John W. Paul Cau~uel January 31, 1994 nFr -1'JFr~ Ms. Kathy Dolan Colorado Department of Health 4300 Cherry Creek Drive South Denver, Colorado 80222-1530 Ms. Susan L. Burgmaier Colorado Department of Natural Resources Division of Minerals & Geology 1313 Sherman Street #215 Denver, Colorado 80203 Re: Public Notice Comments The Pittsburg & Midway Coal Mining Co. Edna Mine; CDPS No. CO-0032638 Dear Ms. Dolan and Ms, Burgmaier: FEd 3 19~~( e~ •;~:~ ' ~ i.~,.; Mfr . ~ L.C„CO~~ Mr. Jon Kubic's letter of July 6, 1993 regarding the draft renewal permit for the Edna Mine was forwarded to me for comment. I would like to offer some points for your further consideration. I understand that the Colorado Mined Land Reclamation Division ("Division") has administratively proposed that so-called "spoils springs" are considered to be any water that has gained mineral content "due to disturbances during mining activities." Such a standard ignores the legal distinction between "point sources" and "non-point sources." The Colorado and federal laws define "point source"' but are silent as to the definition of nonpoint sources. An early EPA publication noted: Nonpoint sources, while not defined in the Act, are, by inference, the accumulated pollutants in the stream, diffuse runoff, seepage, and percolation contributing to the degradation of the quality of surface and ground waters. They include the natural sources (seeps, springs, etc.) (Emphasis added.)Z Colo. Rev. Stat. 525-8-103 (1989); 33 U.S.C.A. 51362(14) (Supp. 1993). Guidance for Areawide Waste Management Treatment Management Planning, U.S. EPA 6-1 (August 1975).