2009-03-19_APPLICATION CORRESPONDENCE - C2008086

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• Washbay • Covered storage • Sewage treatment plant • Water tank • Water treatment building • Water pipeline and diversion • Coal storage piles • Unit train loadout • Coal preparation plant • Mine access roads Mine vent fan I _ The effects to the four endangered Colorado River listed fishes, described in the BA, included effects due to the depletion of 724 acre-feet of water from-the Colorado River system and described the potential for spills of hazardous materials. The BA described that other effects to the fishes such as spills etc, are very unlikely due to measures in place to contain any spills and prevent toxins from reaching the river system. The BA also listed the potential for mixing of mine water discharge and surface water, but concluded that the only adverse effect to the listed fishes would be due to depletions. After a review of the January 2009 Draft Environmental Impact Statement (DEIS) for the Red Cliff Mine, there are several project actions that raise concern. First, CAM holds a water right for 3 cubic feet per second (cfs) (2,172 acre-feet); however, to date CAM has only considered a 724 acre-feet (Icfs) depletion. If CAM plans to utilize its full water right, additional consultation will be required. Second, in Section 4.5 CAM makes the argument that because existing groundwater quality is already poor, potential infiltration from the waste pile will not degrade groundwater, and that sediment and selenium contributions to the Colorado River would be insignificant. However the information provided in the DEIS is inadequate to support these claims. The baseline groundwater quality data provided on page 3-74 of the DEIS shows very high concentrations of selenium. The average dissolved selenium concentrations for each of the monitoring wells tested exceeded the State groundwater standard. It appears that the mining operation is expected to intercept this groundwater and it will be necessary to pump approximately 800-1,000 gallons of water from the mine (page 4-108). It is unclear. how CAM plans to manage this pumped water. If this water is to be discharged as surface water, it far exceeds the Colorado aquatic life water quality standard for dissolved selenium (CDPHE 2008). Another concern that remains to be addressed is the discharge from the proposed sewage treatment plant. We did not find a description of the quantity, quality or location of discharge expected from the sewage treatment plant proposed. Further, no information is provided for the wash bay regarding what quality or quantity of wastewater will be generated, and methods for disposal of wastewater. Many sedimentation ponds are proposed. The DEIS is unclear as to the quality of the water expected to be stored in these ponds. It appears that the ponds are expected to store storm water runoff from the coal waste-rock pile, encountered groundwater, sewage plant discharge, and other waters potentially exceeding state water quality standards. We recommend that all coal waste rock piles, as well as all sedimentation ponds be lined to reduce wastewater infiltration and contamination of groundwater. Another impact inadequately addressed is the use of fire retardant chemicals. As stated on page B-62, fire retardant chemicals may be used along the rail line. It is unclear what measures will be taken to ensure that these chemicals are not allowed to reach surface waters. Each of the project actions listed in the paragraph above has the potential to affect the,four federally endangered Colorado River fishes, and these actions have not been addressed in consultation to date. We believe that further. consultation may be necessary, and recommend 2