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~" `~~`~~~Kennecott <br />~~ <br />F "?s~' t, ~ <br />-~:r Energy <br />C®EOVayo Coa9 Minn <br />571 . rt E i~ih~+~~ 13 <br />Meer er c nlu~ado 816a I <br />Telcf~nonr !9101 a2A-1E~31 <br />F:,x 1970 8?4 1698 <br />Kurds R. BIUM <br />~nvironmen4al Teehnixian <br />March 7, 2005 <br />Mr. Jeff Coombe <br />Colorado Dept. of Public Health and Environment <br />Water Quality Control Division <br />4300 Cherry Creek Drive South <br />Denver, CO 80222-1530 <br />RECEIVEp <br />MAR 0 8 2005 <br />Division of Minerals and Geebsy <br />RE: NOTIFICATION OF LABORATORY ERROR RESULTING IN INABILITY TO ANALYZE NPDES <br />DISCHARGE SAMPLES DATED FEBRUARY 10, 2005 FROM OUTFACES 001A AND 003A FOR TOTAL <br />SUSPENDED SOLIDS (TSS). <br />Deaz Mr. Coombe, <br />Colowyo Coal Company L.P. (Colowyo) is sending notification and explanation of a laboratory error that <br />resulted in the disposal of bottles necessary to complete analyses for Total Suspended Solids (TSS) from <br />samples taken on February 10, 2005 from Outfalls OOIA and 003A. <br />Colowyo received the laboratory report for the above-mentioned samples on Mazch 4, 2005. The report was <br />reviewed one half hour after it was received. It was discovered that these samples were not analyzed for TSS. <br />Tony Antalek (ACZ Laboratories Project Manager) was contacted immediately and asked to provide an <br />explanation why the required analyses were not performed, Colowyo received communication from Mr. <br />Antalek on March 7, 2005 that a laboratory technician had inadvertently disposed of the sample bottles before <br />analysis was performed. <br />Communication with Mr. Antalek stressed the importance of immediate notification to Colowyo upon the <br />discovery of any issues related to compliance samples. Issues with reporting exceedance of holding time and <br />prompt analysis were also discussed as a result of the Total Dissolved Solids (TDS) analysis and pH <br />parameters displaying the "H" designation suggesting that these pazameters were analyzed beyond their <br />allowable holding times. As a result of this discussion, it was clarified that pH is considered a field parameter <br />with an "immediate" hold time. Additionally, the extended qualifiers section of the report explained that the <br />initial analyses of TDS for OOlA and 003A samples were completed within hold time, but failed the Quality <br />Control criteria, leading to reanalysis for this pazameter beyond the allowable hold time. <br />Colowyo acted in good faith to comply with the requirements of the CDPS Permit by taking the samples in a <br />timely manner and submitted them to ACZ laboratories in a timely manner. However, due to the <br />aforementioned reasons, certain activities are out of Colowyo's control. As per the Water Quality Control <br />Division requirements, Colowyo is providing notification within five days of any potential non-compliance <br />with CDPS Permit requirements. <br />Antelope Mine • Lnlowyn Mule = Catlero Rr,~p Vlore • Jacob; Ranch Mine • Spnny Greeh Mina <br /> <br />