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'r. <br />L <br />.' <br />BEFORE THE <br />~. <br />WALTER QUALITY CONTROL DIVISION <br />STATE OF COLORADO <br />IN THE MATTER OF <br />PROPOSED NPDES PERMIT <br />ON APPLICATION OF THE <br />CORPORATION FOR THE <br />SCHWARTZWALDER MINE <br />RENEF]AL ) <br />COTTER ) <br />PERMIT N0. <br />CO-00001244 <br />COMMENTS BY THE ENVIRONMENTAL <br />DEFENSE FUND IN RESPONSE TO <br />NOTICE OF PUBLIC HEARING <br />The Environmental Defense Fund supports most of the <br />provisions of the draft NPDES permit which was the subject <br />of public notice on October 30, 1981. But EllF objects to <br />certain provisions of the draft permit as set out below. <br />I. Monitoring. <br />~~7-3~~ <br />The permit fails to require monitoring adequate to assure <br />compliance with the effluent limitations contained in the permit <br />or the water quality standards on which they are based. As a <br />result, the permit as a whole is inadequate to protect the public <br />health from excessive exposure to toxic pollutants in the dis- <br />charge, including exposure to radioactivity from uranium discharged <br />from the mine. <br />As proposed, the draft permit establishes two effluent limita- <br />tions for uranium and a number of other toxic metals: one is a <br />maximum daily concentration, the second is expressed a.s a 30-day <br />average concentration in the discharge from the minircc operation. <br />But the monitoring requirements in the permit acid the monitoring <br />practices of the Division will allow Cotter to consistently violate <br />the 30-day average concentration. <br />The 30-day average limitations are set at the level of the <br />water quality standard because the 47-10 is zero (0) i:or the <br />receiving stream. In addition, EDF has conducted a welter balance <br />analysis of the Ralston Creek drainage and its contriY~ution to <br />docvnstream municipal water systems. Based on that analysis, 7;DF <br />concludes that adequate long-term protection of the public from <br />