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WESTERN MINING ACTION PROJECT <br />?e <br />Roger Flynn, Esq., <br />Jeffrey C. Parsons, Esq. <br />P.O. Box 349 <br />440 Main Street, Suite 2 <br />Lyons, CO 80540 <br />(303) 823-5738 <br />Fax (303) 823-5732 <br />uvmap?Fij?_, a.org <br />May 14, 2010 <br />Mr. David Bird <br />Reclamation Specialist <br />Colorado Division of Reclamation Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />?111Y 1 2©10 <br />710 01biVion of Reclamattoh, <br />Mining g Safety <br />RE: Cotter Corporation, Schwartzwalder Mine Permit No. M-1977-300; <br />Environmental Protection Plan (EPP), TR11 <br />Dear Mr. Bird: <br />Thank you for the opportunity to provide these comments on the revised Environmental <br />Protection Plan (EPP) submitted by the Schwartzwalder Mine operator, Cotter Corporation, on <br />April 20, 2010. These comments are submitted on behalf of Environment Colorado, a state-wide <br />conservation and advocacy group with hundreds of members in the Arvada and greater Jefferson <br />County area who are potentially directly affected by the contamination issues at the mine site. <br />As you are aware, the serious radioactive water contamination issues at this site have caused <br />a much heightened level of public awareness of this inoperational mine site and the potential threat <br />it poses to drinking water supplies on the Front Range, among other threatened natural resources. It <br />is imperative that the Division take all action necessary to ensure cleanup at this site in an expedited <br />manner. In doing so, the Division should adhere to the recommendations set forth by the Colorado <br />Water Quality Control Division (WQCD) to institute an aggressive pollution source remediation <br />plan and an active water treatment plan to clean the water at the site. In conducting its review, the <br />Division should ensure that the EPP is processed in accord with the Mined Land Reclamation Act <br />and Mined Land Reclamation Board regulations. Lastly, because of the significant costs that are <br />likely to be associated with reclamation of this site moving forward, the Division should take the <br />opportunity now to review and update the financial assurance amounts for this site. <br />In conducting its review of the EPP and in selecting a reclamation strategy for the site, the <br />DRMS should follow the strong advice presented to it by the WQCD as set forth in the WQCD's <br />May 10, 2010 memo on this issue, which is included in the mine reclamation permit file. Therein, <br />WQCD strongly recommends extensive reclamation activities to ensure protection of water quality. <br />Among these needed actions are requiring complete removal of the alluvial fill material coupled <br />with active water collection and treatment of seeps, springs, and groundwater to assure attainment