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MOUNTAIN COAL <br />1-(OMPANYL.L.C. <br />A Subsidiary of Arch Western Resources, LLC <br />December 10, 2008 <br />r <br />Mr. Tom Kaldenbach <br />Colorado Division of Reclamation Mining and Safety <br />Office of Mined Land Reclamation <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />West Elk Mine <br />P.O. Box 591 <br />5174 Highway 133 <br />Somerset, CO 81434 <br />(970) 929-5015 <br />Fax (970) 929-5595 <br />Re: Mountain Coal Company LLC (MCC), West Elk Mine; Permit No. C-80-007; NPDES <br />Permit No. CO-0038776, 4th Quarter 2008, Exceedances (2) - Analytical Reports. <br />Dear Mr. Kaldenbach: <br />MCC is submitting the attached analytical reports as required by the rules regarding these reported <br />exceedences for 4th quarter 2008. MCC is currently working with the CDPOH&E-WQCD to modify <br />the permit regarding the Waste Water Treatment Plant (WWTP) Outfall 007 as the existing limit for <br />Total Suspended Solids (TSS) is not representative of industry guidelines. MCC met with the WQCD <br />Permit Unit on September 1, 2008 to discuss 1) increasing the effluent limit for TSS to 75 mg/L for the <br />30-day average and 110 mg/L for the 7-day/daily maximum based on requirements in Regulation 62 <br />and 2) performing mass loading reporting rather than a percent removal requirement. The permit <br />modification was submitted to the WQCD October 30, 2008. <br />MCC requested relief from the 85% effluent TSS removal requirement because, while not indicative of <br />the efficiency of the plant, the grey water influent is so low in TSS, MCC has a difficult time meeting <br />the 85% removal requirement at the effluent. However, until the submitted permit modification is <br />approved by the WQCD, this is an exceedance of the current permit limit. <br />The exceedances at Outfall 007, occurred November 4, 2008, when effluent TSS was 33 mg/L which <br />exceeds the limit of the 30-day average of 30 mg/L in the current permit. The influent was 80 mg/L <br />TSS, therefore, the calculated value for % removal is only 41%. It appears the WWTP was operating as <br />designed at the time the exceedance occurred. MCC is investigating to determine if there is any <br />outside interference that could be contributing to the effluent TSS. <br />Outfall 007 is an internal discharge. This means the water must pass yet another discharge point (M13- <br />2R, Outfall 004) before it can be discharged. To date in the 4th quarter 2008, Outfall 004 is in <br />compliance with the TSS limits of 35 mg/L TSS for the 30-day average and 75 mg/L for the 7-day <br />average and daily maximum.