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• YVCC Yampa Valley Coal Corporation ~ 29588 Routt County Road #27, Oak Creek, CO 80a67 • (3031 879-3800 January 29, 1987 Brent Anderson Reclamation Specialist Colorado Mined Land Reclamation Division 1313 Sherman Street, Room 423 Denver, CO 80203-2273 Dear Mr. Anderson: impoundments - Mine 3, VErmtt G-tf4-Ub"L The following responses have been prepared in order to address MLRD's adequacy comments as outlined in your January 22, 1987 letter. In order to • facilitate MLRD's review, the responses are preceded by MLRD's comments. 1). The manganese content in the effluent from pond M3-S varies from 0.6 to 0.8 mg/1. This concentration is three to four times the EPA agriculture standard of 0.2 mg/1. (EPA Water Quality Criteria, 1972). CYCC needs to discuss the effects that the manganese exceedences may be expected to have upon livestock and wildlife which can be expected to use the stock ponds. Response: CYCC does not believe there are any exceedences and anticipates no detrimental effects upon livestock or wildlife. "Manganese is not known to be a problem in water consumed by livestock. ... Thus, no specific criterion for manganese in agricultural waters is proposed." (EPA Water Quality Criteria, 1976). Furthermore, the Colorado Department of Health Water Quality Control Commission standard for total manganese on the Yampa River and its tributaries is 1.0 mg/1. 2). Periodic maintenance of the ponds will be required if the ponds are to be permanent and used for stock watering. CYCC needs to propose a maintenance plan which will insure that the stock ponds will be permanent, functional facilities. Response: Prior to bond release, CYCC will maintain these ponds in compliance with Permit C-84-062 and its NPDES permits which currently consists of quarterly inspections. Maintenance following bond release will be the liability of the surface owner. CYCC's ranching operation inspects • and performs necessary repairs on all stock ponds on a regular basis (minimum annual inspections). 3). The twenty-five year life of the ponds depends upon cleaning of the ponds immediately prior to bond release. CYCC needs to explicitly Ex. 3-37(a)