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TECHNICAL REVISION REQUEST <br />Permit No. M-1977-300 <br />The following Technical Revision Request follows the format contained in the May 19, <br />2010 letter from DRMS to Cotter Corporation. <br />1. Reinitiate a water treatment system to treat all water that reports to Sump <br />Number One as soon as possible, but no later than July 31, 2010. In addition to <br />compliance with CRS 34-32-101 and the associated regulations, the plans must include <br />direct coordination with the Colorado Department of Public Health, and must be in <br />compliance with all applicable water quality laws and regulations. <br />Response to #1 <br />Cotter has begun the tender process to secure engineering consultants, construction <br />contractors, and a water treatment company to commence treatment of all water that <br />reports to Sump Number One no later than July 31, 2010. The program will be developed <br />and implemented in accordance with regulation and guidance from applicable agencies <br />(DRMS and CDPHE). The Water Quality Control Division (WQCD) has been notified <br />of plans to initiate water treatment. Cotter will provide proposed treatment and discharge <br />information requested by WQCD as soon as related technical details have been assessed <br />(expected by June 11, 2010). The water treatment company Cotter is presently utilizing is <br />in contact with the Radiation Management Unit of CDPHE to ensure the facility will be <br />suitable for licensing. CDPHE expects that a license will be in place by June 18, 2010. <br />In parallel to the above activity, Cotter will be seeking modifications which will eliminate <br />the need to treat water indefinitely. One possible modification is an isolation barrier <br />system to prevent flow of Ralston Creek water into the alluvial fill. <br />2. Reinitiate mine water dewatering and water discharge treatment sufficient to <br />bring the mine water table to a level at least 500 feet below the Steve Level, and sufficient <br />to reestablish a hydraulic gradient away from Ralston Creek. Implementation must <br />occur as soon as possible, but no later than July 31, 2010. In addition to compliance <br />with CRS 34-32-101 and the associated regulations, the plans must include direct <br />coordination with the Colorado Department of Public Health, and must be in compliance <br />with all applicable water quality laws and regulations. <br />Response to 42 <br />Whetstone Associates has concluded that potential communication between the mine <br />pool and Ralston Creek is minimal and any respective conduits are likely confined to the <br />alluvial fill area. In addition, the available data does not provide convincing evidence that <br />treating mine pool water directly would result in significant improvement in stream water <br />quality. If however, the proposed course of action provided above does not prove that the <br />contaminants are confined to the alluvial fill, a mine pool alternative will be <br />implemented.