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© Tama M atri ~c <br />MONTGOMERY WATSON <br />Mining Group <br />September 22, 1997 <br />Ms. Cazla Leakey <br />Colorado Department of Public Health and Environment <br />WQCD-Permits-B2 <br />4300 Cherry Creek Drive South <br />Denver, Colorado 80246-1530 <br />(303) 692-2000 <br />Re: Kerr Coal Company -Marc Mine (Permit No. COG-850037, Jackson County), <br />Response to Notice of Significant Noncompliance <br />Deaz Ms. Leakey: <br />[n response to your letter of September 4, 1997 re: Notice of Significant Noncompliance; <br />Kerr Coal Company (Kerr) submitted two sepazate requesu for stormwater exemption <br />• (attached for your reference) dated April 15, 1997 and July 2, 1997 addressing the <br />exceedances for Total Suspended Solids and Total Iron for the reporting periods 3/97 and <br />6/97 as identified in your letter. The requested exemptions were granted by the WQCD as <br />documented by a letter from Mr. Jon Kubic, of the WQCD, to Mr. James Mossman, of <br />Kerr, dated July 11, 1997 (letter attached for reference). Given that Kerr has submitted the <br />required stormwater exemption requests for the periods of concern, and that they have been <br />accepted by the WQCD, there does not appear to be any basis for a determination of <br />noncompliance under the existing permit nor a need for further anion. <br />The noted exceedances result from several factors which are beyond the control of Kerr, as <br />the permittee, including natural drainage and runoff conditions in the azea, high levels of <br />extremely fine sedimenu which cannot be readily removed by conventional means, and <br />elevated storm runoff volumes associated primarily with spring snowmelt. The following <br />documentation is provided as background for your review and reference as attachments co <br />this response. The attached documentation provides the historical perspective necessary for <br />you to understand both the problems we are dealing with and the negotiated solution (i.e.: <br />stormwater exemptions) jointly developed between Kerr and the WQCD to address permit <br />compliance, given site conditions: <br />• 8/20/92 Letter from R. Bartell co A. Ihlenfeldt (documenu naturally high <br />baseline levels of TSS and iron in area drainages and describes existing mine <br />drainage and sediment control measures) <br />• <br />P0. Box 77x018 Tel 970 879 6760 Su:•~~g me ::v~ro s =~>~~vi.:~a-+ri .7?e,i, <br />Id75 Pane Grove Road Fax: 9708799068 <br />Swamhoai Springs, Caiorano <br />eoan <br />