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- . `J. -problem, as evidenced~oy NWCCOG's 1996 White Paper•the subject. The White • • ~ Paper was based on the Health Department's Section 305(b) report. It noted that 9 out of 12 publicly owned reservoirs/lakes on the Arkansas were eutrophic. The Division should ensure that the Parkdale Project does not in any way contribute to this problem. The Project's proposed sedimentation ponds raise a number of questions as well. First, has the applicant applied for an NPDES permit for the discharge from these likely unlined ponds into the Arkansas system? The fact that the ponds may first seep into local groundwater before reaching a surface stream does not disqualify the ponds as point sources under the Clean Water Act. What sediment loading will result from the ponds? Along these lines, what are the short and long-term operation/maintenance/treatment costs associated with these ponds/berms? Under state law, such costs must be included in the required bond before the application can be approved. The application notes that process water will be pumped from a well in the process plant area. How does the applicant propose to augment these losses from the over- appropriated Arkansas system? In addition, how will the applicant replace water lost due to potential evaporation from the ground water exposed by the mine pit? The Construction Material Rules clearly require that an applicant assure that all water quality and quantity laws will be complied with. See e•e•• Rule 3.1.6. Such a showing must be made prior to permit approval. How does the applicant propose to ensure that process waters released into the pits meet all applicable water quality standards, including those designed to protect surface flows that are likely hydrologically connected to the ground water impacted by the pits? What is the projected quality of the process water? For all of these water quality and quantity issues, what will be the impacts to local aquatic life? These serious water concerns must be addressed prior to permit approval. Some of these concerns were raised by the Division in its September 9, 1997, letter from Larry Oehler to Mitch Albert. At a minimum, all of the needs addressed in that letter must be completely satisfied before the Division can proceed with the application review process. In addition, the issues raised in this letter must also be resolved before the Division can judge the application complete. We appreciate the opportunity to comment on this important project. Sincerely, Carmi McLean David Nickum Clean Water Action Trout Unlimited JO ~ )o Evans Environmental Information Services cc Doug Young Tom Kenyon