2010-05-17_REVISION - M1977300 (2)

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WESTERN MINING ACTION PROJECT Roger Flynn, Esq., Jeffrey C. Parsons, Esq. P.O. Box 349 440 Main Street, Suite 2 Lyons, CO 80540 (303) 823-5738 Fax (303) 823-5732 w m aptt ig-o.ory May 14, 2010 w _ Mr. David Bird Z Reclamation Specialist Colorado Division of Reclamation Mining and Safety 1313 Sherman Street, Room 215 Denver, CO 80203 Flily 1 2®10 _0 0IVISIon of Reclamatlah, Mining & Safety RE: Cotter Corporation, Schwartzwalder Mine Permit No. M-1977-300; Environmental Protection Plan (EPP), TR-11 Dear Mr. Bird: Thank you for the opportunity to provide these comments on the revised Environmental Protection Plan (EPP) submitted by the Schwartzwalder Mine operator, Cotter Corporation, on April 20, 2010. These comments are submitted on behalf of Environment Colorado, a state-wide conservation and advocacy group with hundreds of members in the Arvada and greater Jefferson County area who are potentially directly affected by the contamination issues at the mine site. As you are aware, the serious radioactive water contamination issues at this site have caused a much heightened level of public awareness of this inoperational mine site and the potential threat it poses to drinking water supplies on the Front Range, among other threatened natural resources. It is imperative that the Division take all action necessary to ensure cleanup at this site in an expedited manner. In doing so, the Division should adhere to the recommendations set forth by the Colorado Water Quality Control Division (WQCD) to institute an aggressive pollution source remediation plan and an active water treatment plan to clean the water at the site. In conducting its review, the Division should ensure that the EPP is processed in accord with the Mined Land Reclamation Act and Mined Land Reclamation Board regulations. Lastly, because of the significant costs that are likely to be associated with reclamation of this site moving forward, the Division should take the opportunity now to review and update the financial assurance amounts for this site. In conducting its review of the EPP and in selecting a reclamation strategy for the site, the DRMS should follow the strong advice presented to it by the WQCD as set forth in the WQCD's May 10, 2010 memo on this issue, which is included in the mine reclamation permit file. Therein, WQCD strongly recommends extensive reclamation activities to ensure protection of water quality. Among these needed actions are requiring complete removal of the alluvial fill material coupled with active water collection and treatment of seeps, springs, and groundwater to assure attainment