1994-12-05_GENERAL DOCUMENTS - C1981017

Home Browse Search

r STATE OF COLORADO Roy Romer,Governor Of'Co Patricia A.Nolan,MD,MPH,Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Buildin$ Denver,Colorado 80222-1530 4210 E.11th Avenue ~1876 �� C Phone(303)692-2000 Denver,Colorado 80220-3716 C /v (303)691-4700 �D Colo"Department of Public Healdi Water Quality Control Division D`v 05 1n94 and Etivu Onmtnt WQCD-PE �7 (303)+692-3500 FAX(303)+782-0390 Division of Minerals &Geolo9Y December 1, 1994 Robert Delaney Executive Vice President and General Counsel Mid-Continent Resources, Inc. 818 Colorado Avenue P.O. Drawer 700 Glenwood Springs, CO 81602 RE: Salinity Report Mid-Continent Resources, Inc. - Coal Basin Mines CDPS No. CO-0000396 Pitkin County Dear Mr. Delaney: This letter responds to your October 28, 1994, letter that responds to the renewal permit requirement for submission of a Salinity Report (Part I.A.5.). Your letter does not address the permit requirements. We acknowledge the facts stated in your letter including that the site is being reclaimed by the Colorado Division of Minerals and Geology and that Mid-Continent Resources, Inc. ("Mid-Continent") is in Chapter 11 bankruptcy. However, because Mid-Continent remains the permittee for the CDPS permit it is necessary for Mid-Continent to submit a salinity report. The permit requirement can be fulfilled relatively simply. It is unlikely that there currently is an economically feasible method of satisfactory salinity treatment for the facility's discharges. Commonly available references should document costs for typical treatment such as reverse osmosis and/or containment, which would consume several acres of land and potentially impact water rights. From these references, Mid- Continent should be able to prepare a short report that demonstrates through three treatment and/or containment scenarios that the costs associated with salt reduction at this site would be economically infeasible generally and especially so in Mid-Continent's case. Once such a report has been submitted, reviewed and approved, the Division could be justified in determining that the permit requirement had been satisfied. We have included a copy of the Regulations for Implementation of the Colorado River Salinity Standards Through the NPDES Program, 3.10.0 (5 CCR 1002-11) for additional related information. Section 3.10.4 I.B. specifically addresses these requirements.