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;, iii iiiiiiiiiiiu iii 999 COAL' COMPANY Mr. Dan Mathews Environmental Protection Specialist Colorado Division of Minerals and Geology 215 Centennial Building 1313 Sherman Street Denver, Colorado 80203 Mr. Robert J. Shukie, Chief Permits and Enforcement Section Water Quality Control Division 4300 Cherry Creek Dr. S. Denver, Colorado. 80222-1530 5731 State Highway 13 Meeker, Colorado 61641 1303) 824451 August 4, 1994 RErEn~E(~ AUG 1 y 1994 Dit-!5,00 of hi:nerals ~ ueuio9Y RE: Memorandum of Understanding Between DMG and WQCD Gentlemen: It has come to our attention that the Division of Minerals and Geology (DMG) and the Water Quality Control Division (WQCD) are currently in the process of finalizing a memorandum of understanding (MOU). The purpose of the MOU is to address a number of issues concerning the division of responsibilities with respect to enforcement of effluent and stormwater permit conditions at coal mines in Colorado. We understand that the WQCD will be responsible for the enforcement of Colorado Discharge Permit System (CDPS) permit conditions while DMG will be responsible for enforcement on effluent exceedances, but only for DMG collected information. In terms of enforcement, DMG will be applying federal effluent guidelines set forth in 40 CFR Part 434 rather than CDPS permit conditions. two separate State agencies, This raises a major concern to Colowyo since particular discharge standards of recent CDPS permit renewals currently conflict with the applicable federal effluent guidelines. Once this MOU is in effect, Coal mines in Colorado will be jeopardized by the enforcement of two differing sets of effluent standards by The specific conflict concerns the applicable standards for sediment pond discharges resulting from precipitation less than, equal to or greater than a 10-year, 24-hour event (or snowmelt). The requirements of our CDPS permit have been recently modified