GENERAL41136

• Permit No: C1981028
• IBM Index Class Name: General Documents
• Doc Date: 6/12/1995
• Doc Name: Letter on Requirements for Ash Disposal
• From: DMG
• To: COORS ENERGY CO
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

~L
STATE OF III III III III IIII III
COLORADO
DIVISION OF MINERALS AND GEOLOGY
Depanment of Natural Resources
1317 Sherman 51., Room 215 L

Denver, ColoraAo 80203 ~
~
~

Phone: [phone] ~
I
FAX: [phone]
DEPARTMENT OF
NATURAL
RESOURCES

June 12, 1995 Roy Romer
Governor
lame 5 Lx hheaA
Coors Energy Company Eteculive Director
Mr. Donald W. MacDonald, Mgr. Energy Services Mic hael B. LOng
P.O. BOX 467 Dinsion Dueaor
Golden, Colorado 80402
RE: Keenesburg Strip Mine, File No. C-81-028
Dear Mr. MacDonald:
The Division has received two items of correspondence from Coors
Energy Company (CEC) relating to the disposal of ash at the
Keenesburg Strip Mine. The first is a letter dated March 15, 1995
stating CEC's position concerning the submittal of a technical
revision with respect to changing the coal source and waste ash.
The second is a cover letter and report of analysis dated May 4,
1995 for the waste ash from the new coal source. Both letters are
in response to Minor Revision 27 (MR-27) which was approved to
dispose of test burn ash at the Keenesburg Strip Mine for a 60 day
period. One requirement of the MR-27 approval was to perform the
required laboratory analyses as outlined in the current mining and
reclamation permit and the second was to submit a technical
revision if a permanent switch in the coal supply was implemented.
With respect to the first letter, MR-27 was approved for a 60 day
test burn only. Please be advised that disposing of the new coal
source ash beyond the 60 -day period approved in MR-27 may result in
an enforcement action against CEC. If CEC made a decision to
switch coal suppliers, a technical revision was to be submitted,
reviewed and approved to reflect the new coal source. CEC's letter
indicates their belief that a technical revision is not necessary
based on the definition of a technical revision and the fact that
the permit is silent on the source of the coal (which it is not,
see TR-13). The letter goes on to say that the permit neither
requires or prohibits the disposal of ash from any specific source.
The DMG mining and reclamation permit does contain restrictions and
requirements for the disposal of ash at the Keenesburg Mine
including providing laboratory analyses of ash from any new coal
source. In addition, the special use permit issued by Weld County
was required as part of the approval for TR-13 and clearly states
that if the coal source is changed, review and approval of the new