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Septemlxr 1993 Xm Coal Company ~ 3 6) Regular monitoring of both discharge water levels and water quality in Pond A to maintain adequate stormwater storage capacity and verify compliance with discharge effluent limitations 1J What is the water quality of the pit? Response: Until recent reclamation activities were ini[iated, access to the area of impounded water was limited by physical constraints and safety considerations. While there is still no vehicular access to the pit bottom, pedestrian access has been recently established. Kerr will obtain representative pit water samples within the next 30 days and will have the samples analyzed for the pazameters identified in the Kerr Monitoring Plan for Sample Type D. A copy of [he laboratory analysis results will be forwarded to the DMG for reference and review on receipt. Kerr also plans to collect additional samples which could be used for laboratory treatmen[ testing in the event that the water quality analyses indicate the need for treatment to meet applicable effluent standards. 3J Kerr should update the dewatering plan to rover the 720 Pit. Pages 780-107aaR of the permit application addresses the dewatering of Pit No. 2 to Pond H but dewatering of the 710 Pit is not addressed. A demonstration should be submitted to show that Pond A has the spare capacity to treat the 720 Pit prrmpage and simrrltaneorrsly haze the capacity to treat the 10 year, 24 hour event. How will the pond level 6r monitored to maintain the storm capacity? Response: Accompanying these responses is a revised discussion of dewatering plans reflecting consideration of pit water discharge requirements for the 720 Pit. The revised discussion is formatted for insertion replacement in the Kerr Permit Appliption Document. The concern relative to maintenance of stormwater retention capacity, water management for Pond A or any other ponds utilized for storage, retention, and treatment of pit water discharge flows, and water level monitoring is addressed by Response 1 above. The key to effective water management and compliance with applicable regulatory requirements will be control and scheduling of pit water discharge. 4) Kerr should submit a letter from the Health Department NPDES approving the pit water discharge under a general NPDES permit. /jthe water cannot be discharged under a general permit then Kerr should apply for an individual permit. Response: Review of the current CDPS Permit (Permit No. COG850021) and phone conversations with Colorado Department of Health -Water Quality Control Division (IX/QCD) staff indicate that as an inactive mine, pit water discharge may be covered under the general permit (COG850000). Accompanying these responses is a copy of a letter transmitted to WQCD requesting verification that pit water discharge is included under the general permit. As noted in the letter, we have requested that DMG be copied on all related correspondence. a~..wo7a~onoc wiavvt •pm ACZ Inc. • P.O. Bos 774018 • Srmmbmt Sprirsg; Colorado 80477 ` (103f 879-6260