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<br />103. Because the roads related to these questions were existing at the time the Roadside permit <br />(a & f) was originally issued, PCC has used the roads as part of its operations since that time, and <br />no performance problems with the drainage structures in question have been observed, no <br />further response to this question is necessary. Should the roads be substantially modified <br />or "upgraded" in order to accommodate mining operations in the future ,they would need <br />to meet regulatory performance standards at that time. <br />103c. Please clarify any discussion in the permit -rgazding the use and maintenance of this road <br />by Public Service Company, and any correspondence from the Colorado Department of <br />Public Health and Environment regarding treatment of runoff from the area. It would <br />also be helpful to include a brief discussion of how the runoff from the road and the fly <br />ash disposal area is collected and conveyed. The Division will take these factors into <br />consideration in making any findings about PCC's obligations with this road. We will <br />contact PCC on this matter prior to making any of these findings as part of the proposed <br />decision package for the pending permit revision. <br />123. Our previous request for copies of past paper work related to construction of refuse piles <br />was made in an effort to complete our records. The Division is not requiring that these <br />records be provided as a matter of regulatory compliance. If those records do not exist, <br />or if PCC does not care to provide copies of records which may have been previously <br />submitted, no further response to this question is necessary. We would appreciate your <br />assistance in completing the set of records which the Division maintains for review by the <br />public and federal oversight. <br />On another note, we also discussed PCC's proposed plans for treating mine water from the <br />Roadside North portals. I would like to reiterate that the Division's only goal in this undertaking <br />is to ensure that all mine water discharges meet the relevant effluent limitations. You mentioned <br />a concern that the Division was limiting PCC's at-_lity to consider treatment plans. If PCC <br />anticipates flaws in its proposed plan, or wishes to consider alternative plans (i.e., beginning <br />flocculent treatment underground), I would urge you to discuss those plans with the Division as <br />soon as possible. In light of the fact that the Division Director has found a pattern of violations <br />with regard to PCC's recent mine water discharge record, it is imperative that a revised treatment <br />system be implemented as soon as possible. <br />Please contact me or Dan Mathews if you have any questions or wish to discuss any of these <br />matters. <br />Sincerely, <br />~~i~~2G~(LZ~/ <br />Larry Routten <br />Environmental Protection Specialist <br />cc: Dan Mathews <br />