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Attachment A <br />were held to clarify the allocation of responsibility between the various agencies with <br />respect to water quality. The board was apparently satisfied that OOSI would be <br />operating under the Water Quality Control Division with respect to both surface water <br />and groundwater. OOSI had obtained both a NPDES permit for the mine non-process <br />mine water and a subsurface disposal permit both issued by the Water Quality Control <br />Division. <br />A pilot waste water treatment plant was operated From May through November 1982 to <br />treat process condensate water so that this water could be dischazged according to state <br />discharge permits. Discharge requirements were achieved in September of that same <br />year. After quenching of Retorts 7 and 8 from November 1982 to February 1983, retort <br />discharge water was treated through the use of the steam generation facility. <br />In a May 19841etter from OOSI to Mr. Robert Shukle, Industrial Unit Chief, of the <br />Water Quality [Control] Division, the conceptual design of the evaporation pond was <br />discussed. In this letter, OOSI asks the state what other agencies other than the BLM, <br />Ga~eld County, and the State Engineer's Office require involvement or have authority <br />with respect to the evaporation pond design and installation. In a follow-up letter dated <br />June 8, 1984, OOSI confirmed that the final design and construction of the evaporation <br />pond was the "only realistic option for handling retort water ...because of the time <br />frame involved with our discharge amendment." Both of the above letters were copied to <br />the U.S. EPA. The BLM approved aright-of--way for the pipeline and evaporation pond <br />in August 1984. <br />In a March 27, 1985 letter to Mr. Joseph G. Zalkind, Mined Land Minerals Supervisor, <br />OOSI enclosed the 1984 annual report and required submittal fee. The annual report <br />designates Area #23 as the "Evaporation Pond and Pipeline" and that 5.07 acres of a total <br />of 14.87 acres associated with this area had been reclaimed during the yeaz. <br />A Mined Land Reclamation Division (MEAD) inspection report dated October 1, 1985, <br />from Mr. J McArdle to OOSI stated numerous observations including the following: <br />"Water quality from the fired retorts, according to analysis would meet current discharge <br />criteria in approx. 13 years. Inflow HZO is pumped from the fired retorts once per week <br />into the evaporations ponds (approx. 120,000 gallons per week)." A February 13, 1992 <br />inspection by the MLRD also referred to the evaporation pond and that the pond was <br />receiving 3,500 to 4,000 gallons per day. Subsequent MLRD (DMG) inspection reports <br />also cite observations of the evaporation pond. <br />The above information indicates that mining and processing of the retorts was clearly a <br />permitted activity and the generation and treatment and process water was anticipated and <br />discussed with the MLRD {DAMS) in the past. It is apparent that the WQCD was <br />recognized as the regulating authority for management of the mine and retort dischazge <br />waters, Furthermore, it is evident that the evaporation pond was a replacement for active <br />treatment, and that alternative treatment systems were evaluated prior to the construction <br />of the evaporation pond in 1984. <br />3 <br />