2009-09-25_PERMIT FILE - M2009076 ‎(22)‎

• Permit No: M2009076
• IBM Index Class Name: PERMIT FILE
• Doc Date: 9/25/2009
• Doc Name: New 110d DMO Appl- Part I
• From: Venture Resources, Inc.
• To: DRMS
• Media Type: D
• Archive: No

PUBLIC HEALTH AND ENVIRONMENTAL RISKS WHILE PROVIDING AN ECONOMIC RETURN TO THE COMMUNITIES.
A MAJOR CONCERN AT THE SITE THROUGHOUT THE SUPERFUND PROCESS HAS BEEN THE EXTENT TO WHICH EPA'S
SUPERFUND ACTIVITIES MAY ADVERSELY IMPACT LOCAL PROPERTY OWNERS AND FUTURE PROSPECTS FOR MINING.
UMBER OF CITIZENS HAVE EXPRESSED SUPPORT FOR AREA PROPERTY OWNERS, BOTH ENCOURAGING EPA TO
L IT THE FINANCIAL LIABILITIES FOR LOCAL PROPERTY OWNERS, AND DISCOURAGING EPA FROM DESTROYING
OR REMOVING THE MINING WASTES BEFORE THE MINERALS CAN BE EXTRACTED FROM THEM. RESIDENTS
SUGGESTED THAT EPA SHOULD REEVALUATE THE NEED FOR THE CLEANUP AT THIS SITE. RESIDENTS HAVE
CONSISTENTLY SUGGESTED THAT BLOWOUT CONTROL IS IMPORTANT; HOWEVER, FEW APPEAR TO SUPPORT THE
NEED TO CLEAN UP OR STABILIZE THE TAILINGS AND WASTE ROCK PILES. BLOWOUTS ARE LARGE RELEASES OF
MINE DRAINAGE FROM MINES WHOSE TUNNELS HAVE BEEN TEMPORARILY BLOCKED FOR A PERIOD OF TIME
THROUGH NATURAL SILTING OR COLLAPSE OF MINE WORKINGS. THE ARGO TUNNEL HAS EXPERIENCED BLOWOUTS
IN THE PAST, WITH RESULTING CONTAMINATION OF CLEAR CREEK DOWNSTREAM TO GOLDEN. RESIDENTS
CRITICIZED EPA FOR CONTINUING ITS STUDY OF MINE TAILINGS AT THE SITE WITHOUT CONSIDERING THE
LENGTH OF TIME THE TAILINGS HAVE BEEN IN PLACE WITHOUT ANY PERCEIVED ENDANGERMENT OF HUMAN
HEALTH OR THE ENVIRONMENT.
DURING THE PUBLIC MEETINGS, EPA RESPONDED THAT IT WOULD CONSIDER PROPOSALS TO REPROCESS THE
TAILINGS PILES AND THAT THE PROPOSED REMEDIAL ALTERNATIVE WOULD NOT AFFECT THE FUTURE ECONOMIC
VALUE OF THE TAILINGS PILES. THE AGENCY HAS ALSO CONSISTENTLY AGREED THAT BLOWOUT CONTROL IS AN
IMPORTANT ISSUE AND NOTED THAT THE PROBLEM IS CURRENTLY UNDER STUDY.
THE FIRST SUBSECTION BELOW PROVIDES A SUMMARY OF COMMENTS AND EPA'S RESPONSES; THE SECOND
SUBSECTION SUMMARIZES REMAINING COMMENTS FOR WHICH EPA WILL BE ABLE TO PROVIDE MORE COMPLETE
RESPONSES AFTER FURTHER STUDY.
A. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND SPA'S RESPONSES
THIS SECTION CATEGORIZES QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
EPA'S RESPONSES TO THOSE COMMENTS IN THE CATEGORIES BELOW:
- POLICY ISSUES;
STUDY METHODS AND FINDINGS;'
- GOVERNMENT AND SUPERFUND PROCEDURES AND ACTIVITIES; AND
- ECONOMIC ISSUES.
1. POLICY ISSUES
COMMENT: TWO COMMENTERS ASKED WHAT THE COST OF EPA'S STUDIES HAS BEEN TO DATE. ONE OF THESE
COMMENTERS QUESTIONED WHETHER THE HIGH COST OF EPA'S EFFORTS IS WORTH THE OUTCOME.
SPA'S RESPONSE: ACTUAL COSTS OF THE STUDIES TO DATE WERE COMPILED AND SENT TO THE COMMENTERS.
THIS SAME INFORMATION IS AVAILABLE TO ANY INDIVIDUAL WHO REQUESTS IT. WITH REGARD TO THE
TAILINGS AND WASTE ROCK, EPA HAS SELECTED THOSE ACTIONS THAT EFFECTIVELY ADDRESS THE IDENTIFIED
PROBLEMS.
COMMENT: THE COLORADO DEPARTMENT OF HEALTH (CDH) RECOMMENDS THAT OPERABLE UNIT NO. TWO BE
REDIRECTED TO EVALUATE ALL MAJOR SOURCES OF CONTAMINATION FROM MINING WASTE PILES IN THE STUDY
AREA TO DETERMINE THE RELATIVE CONTRIBUTION OF EACH SOURCE, TO DEVELOP A QUANTITATIVE ESTIMATE
OF THE ENVIRONMENTAL IMPROVEMENTS FROM REMEDIATION OF ANY AND ALL SOURCES RELATIVE TO THE
DISTRICT-WIDE IMPACT OF MINING WASTE, AND TO SELECT THE NECESSARY REMEDIATION BASED ON THE
SIGNIFICANCE OF EACH SOURCE. CDH ALSO RECOMMENDS THAT THE SELECTION OF APPLICABLE OR RELEVANT
AND APPROPRIATE REQUIREMENTS (ARARS), WITH RESPECT TO TECHNICAL FEASIBILITY AND COST
EFFECTIVENESS, SHOULD ALSO BE REEXAMINED AS A PART OF THIS REDIRECTED EFFORT.
EPA'S RESPONSE: EPA HAS EVALUATED THE DISTRICT-WIDE IMPACT OF MINING WASTE IN RELATION TO THE
PROPOSED REMEDIATION. EPA RECOGNIZES THE POTENTIAL CONTAMINATION FROM OTHER SOURCES AND THESE
0 URCES WILL BE STUDIED IN THE FUTURE BY THE STATE OF COLORADO. EPA BELIEVES, HOWEVER, THAT THE
RRENT REMEDIES ARE COST-EFFECTIVE AND WILL REDUCE CONTAMINATION TO THE SURFACE WATER.
THEREFORE, THE CURRENT REMEDIATION SHOULD PROCEED AS SCHEDULED.
COMMENT: WITH REGARD TO ARARS, CDH MADE THE FOLLOWING COMMENTS: SELECTION OF THE PREFERRED
ALTERNATIVE WILL REQUIRE WAIVING SEVERAL ARABS, SUCH AS REVEGETATION STANDARDS UNDER THE