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Carl B Mount, 5175 W Ohio Ave, Lakewood, CO 80226 <br />Opinion <br />In light of all the above information, I believe it is imperative that the l7RMS and La Plata County include <br />measures in both of their permits to evaluate the potential water quality impacts of the waste rock <br />repository and change and implement plans in a timely fashion to ensure minimization of adverse <br />effects of runoff and leachate on surface and groundwater (as required by both agency's regulations). <br />This is especially critical because alluvial groundwater under the waste pile may be tributary to Hay <br />Gulch surface water and thus subject to Clean Water Act surface water quality standards. <br />Further placement of waste material must be stopped until the characterization of waste material and <br />designs for proper disposal of the waste material are finalized and approved by the permitting agencies. <br />The currently used waste pile was permitted many years ago with extremely minimal geochemical waste <br />characterization from a static or kinetic perspective. The waste pile is very likely a source of current and <br />future water pollution. The current waste pile doesn't appear to be designed to minimize adverse <br />effects of surface water runoff and leachate from the waste on surface and ground waters as required <br />by the regulations. There is no water monitoring system in place that effectively monitors quantity and <br />quality of surface water runoff or leachate from the waste and thus, the effectiveness of the waste pile <br />design is not being evaluated. No plans are in place to begin monitoring this waste piste. Since there is no <br />effective waste characterization and no monitoring system, the design is impossible to evaluate and its <br />effectiveness is impossible to determine once it is constructed. <br />GCC has delayed finalizing TR20 for more than four years. Allowing GCC to continue to deposit waste <br />rock in the present repository is making the problem worse and more difficult and expensive to correct. <br />Lead, cadmium, fluoride and other toxic constituents have already been noted in elevated levels that <br />exceed Primary Maximum Contaminant Levels for cadmium, lead, and fluoride at the Wittse Well, an <br />alluvial groundwater well in Hay Gulch directly downstream of the present waste pile (Fischer, personal <br />communication and as noted in Brooks, 1985). Monitoring of these constituents is not presently <br />required. <br />Suggestions <br />First, stop further placement of uncharacterized coal mine waste in a waste pile that is not designed to <br />contain soluble and water transportable pollutants from the waste to alluvial groundwater and on to <br />Hay Gulch surface water. The practice of placing mine waste in this manner has most likely already <br />resulted in environmental harm to water resources at this site and at many other mining sites in <br />Colorado. Although there are no monitoring, data at this site, because there has been no monitoring, the <br />practice of placing more waste should be ceased immediately. Based on experience at many other sites, <br />this kind of disposal, especially when the waste has not been characterized, "...can reasonably be <br />expected to cause significant imminent environmental harm to land, air, or water resources (See <br />Colorado Surface Coal Mining Reclamation Act at 34-33-123(1)x." And, given GCC's continued delaying <br />tactics to prevent resolution of this situation, it is now appropriate for the RRMS to issue a cessation <br />orderto halt further placement of waste at this site. To not do so merely compounds a problem that <br />will be difficult to mitigate. <br />Mr. Luke Oaniplwn, Esq. Page 3 <br />9Gng [and n Mine water and Coal Mine Wasto Concern, <br />May 11, 2016 <br />