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1 1 1 1 1 COEORADO DEPARTMENT OF HEALTH Dedicated to protertin8 and improving the health and environment of the people of Colorado 4700 Cherry Creek Dr. S. Laboratory Building Denver, Colorado 80222-1570 4210 E. 11th Avenue Phone 13071692-2000 Denver, Colorado 80220-3716 (3 071 691-4 700 January 4, 1994 Jerry Nettleton TerraMatrix 1475 Pine Crove Road, Suite 109 P.O. Box 774018 Steamboat Springs, CO 80477 RE: One Time Metals Analysis Kerr Coal Co. - Kerr Mine CO-0043567 Jackson County Dear Mr. Nettleton: STATE OF COLORADO of tt,~ ~`~ *~ „~ ~ 'rso Roy Rome Gorvnar PaVida A. Nolan M0, MPH Eaennne Director We have received the faxed copy of the metals analysis results performed in compliance with Part I.B.3. of Kerr's recently issued individual permit number CO-0043567. We recognize that Kerr intends to discharge from only one point rather than the three points originall}• anticipated. Therefore, this analysis fully complies with the intention of Part I.B.3. These results show all metals except potentially dissolved (PD) lead and total recoverable (TR) manganese as less than the detection limits. All metals for which the values are less than detection are acceptable for discharge. The manganese level is one-half of the water quality standard. Thus, manganese is acceptable for discharge. The lead result is 4.8 wg/Y (or 0.0048 mg/Y). The lead standard (referred to as the "TVS" aquatic life standard) is determined by a formula that uses the site-specific instream hardness concentration. We have no site-specific instream hardness data for the immediate receiving waters on file. However, there is a record of the level of hardness in the Michigan River near Walden. The mean value of 100 mg/P (of 85 samples collected between 1971 and 1990) is believed to be representative of the probable hardness in the vicinity of the Kerr Mine, 1 Using this hardness concentration in the TVS formulas for PD lead results in standards of 0.004/0.096 mg/E (chronic/acute); these are equal to potential limitations of the same values (30•day average/daily maxitc~am). The one time analysis result is well below the daily maximum limitation and because the analysis is a single result, the mean of several effluent values may well be below the 30-day average limitation. In addition, the CO Division of Minerals and Geolog}• submitted a copy of results of a sample of the pit water Kerr collected in September, 1993. This sample was analyzed for total recoverable lead, the result was "less than 0.02 mg/F". On the basis of these results, we are concluding that the lead level is probably not likely to impact the receiving water.