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r <br />5) By contrast, pit pumping from the West Pit to the E. Taylor Pond occurred with <br />absolutely unanticipated results. The quality of water was totally unexpected and, regretfully, should <br />never have been pumped to the pond. The water pumped to the pond had elevated levels of suspended <br />solids m total suspension which simply would not settle out. Subsequent analysis of the water indicated <br />almost no settleable solids but a high level of suspended solids. We simply never encountered water <br />like this before in our ponds. <br />6) We aze currently working closely with CDPHE to select a flocculent which will remove <br />the suspended material from the water before dischazging so as to meet effiuent limits. <br />7) The source ofthe suspended material appears to be a combination of 1) finely ground <br />clays and shales and possrbly coal fines from the mining operation being picked up in the surface runoff <br />and 2) pumping of the water twice (to get it out physically of the pit). We speculate that pumping <br />twice probably caused these materials to be further entrained into suspension. <br />8) The NOV abatement steps gave Colowyo two alternatives; 1) redesign the E. Taylor <br />Pond system to handle the poor quality water or 2) resubmit the permit page 4.05-6 to indicate that <br />pit pumping will not take place. Colowyo received the NOV on March 29, 1995 and immediately <br />submitted a request for MR-38 to facilitate the second alternate. Cleazly, until we can determine the <br />best way to handle the poor quality of water pumped recently into the sedimentation pond the better <br />alternative is to simply not pump the water out of the pit into the pond. <br />In conclusion, with respect to the issue of pumping water from the pit into sediment ponds, <br />given the historic quality ofthe water, we believe Colowyo has previously operated appropriately and <br />successfully addressed the Division's concerns through the permitting process. As we have stated <br />many times, our primary objective is to achieve on the ground compliance, and until the recent incident <br />with the poor quality water pumped into the E.Taylor Pond, our record shows we have done so. <br />This recent incident is very regrettable, unanticipated and we were unprepazed to handle the <br />flow ofpoor quality water that would not settle out the suspended solids. By responding immediately <br />to the Division's concerns in the form of a commitment to no longer pump pit water to the <br />sedimentation ponds we have shown that we consider this incident to be extremely important. <br />Please contact me ifyou have any questions concerning this matter. <br />Sincerely, ~ `~-`~ <br />liivrel~ ~ ~U <br />~ames A. I{iger <br />Sr. Environmental Engineer <br />xc: RG. Atkinson <br />KW. Wolf <br />files <br />