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EPP Adequacy Review No. 2 2 19 March 2010 <br />Schwartzwalder Mine File No. M-1977-300 <br />Corrective Action - Pen-nit Technical Revision <br />Cotter must submit a new Technical Revision to Permit Number M-1977-300 no later than June 1, 2010 to <br />include plans and implementation schedules as follows: <br />1. Reinitiate a water treatment system to treat all water that reports to Sump Number One as soon as <br />possible, but no later than July 31, 2010. In addition to compliance with C.R.S. 34-32-101 and the <br />associated regulations, the plans must include direct coordination with the Colorado Department of <br />Public Health, and must be in compliance with all applicable water quality laws and regulations. <br />2. Reinitiate mine dewatering and water discharge treatment sufficient to bring the mine water table to <br />a level at least 500 feet below the Steve Level, and sufficient to reestablish a hydraulic gradient <br />away from Ralston Creek. Implementation must occur as soon as possible, but no later than July 31, <br />2010. In addition to compliance with C.R.S. 34-32-101 and the associated regulations, the plans <br />must include direct coordination with the Colorado Department of Public Health, and must be in <br />compliance with all applicable water quality laws and regulations. <br />3. Detailed financial warranty provisions for the plans must be included with the Technical revision <br />application. <br />4. The plan must acknowledge that Cotter will immediately cease all well abandonment activities, and <br />immediately reinitiate all surface and ground water monitoring. <br />Corrective Action - Permit Amendment <br />Cotter must submit an Amendment to Permit Number M-1977-300 no later than August 1, 2010 to address <br />the unresolved EPP details indicated below. These issues must be resolved to comply with the EPP <br />requirements, and these unresolved issues are the basis for EPP denial decision referenced above. Page <br />references are to pages in the previously submitted and now denied EPP. <br />SECTION 7. FACILITIES EVALUATION <br />1) Operator states on pg 7-3 "...because flow rates from the mine are extremely low, total mass <br />loading from the underground workings is small." Other than the mine inflow rates, is there any <br />direct evidence to support the statement that flow rates from the mine are "extremely low?" <br />2) Operator states on pg 7-3 "Issues related to the flooded mine workings include water chemistry <br />in the mine, flow rates from the mine, potential interaction with water in Ralston Creek, and <br />potential pathways in low-permeability bedrock." This list should also include the possibility of <br />potential ground water pathways in structural conduits such as the Schwartz Trend and perhaps <br />the West Rogers Fault.