2010-08-18_GENERAL DOCUMENTS - M1977300

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Based on a review of the draft Permit fact sheet, the Environmental Protection Plan submitted to the Division of Reclamation Mining and Safety (DRMS), and associated documents, it is requested that the following information be considered in the analysis of the appropriate discharge limits, future monitoring requirements and potential future permit conditions: • What impact does the Carlota decision otherwise known as Friends of Pinto Creek v. United States Environmental Protection Agency, 504 F.3d 1007 (9th Cir. 2007), have on the issuance of the Swartzwalder WWTF Discharge Permit? • Current information from Cotter Corporation's Environmental Protection Plan shows that there are at least four sources contributing to pollutant loadings: 1) the alluvial fill, 2) the mine pool, 3), seep in the alluvial fill area and 4) waste rock. It is not clear if all four sources were included, and what impact all four sources would have on the type of treatment media and treatment plant capacity. • The use of downstream water quality is inappropriate for Baseline Water Quality as pollutant containing waste rock pollutants and treatment residuals from the previous waste treatment facility has been placed in the alluvial thereby degrading water quality. • The treatment media (Z-92) is designed only for uranium removal and does not provide adequate treatment of radium 226 / 228 or gross alpha and gross beta. In considering the revised draft discharge Permit limits it is difficult to understand why the reclamation activity of the former mining operation should not have up stream water quality as the discharge limits. Using background water quality and taking into consideration seasonal variation of the water quality in Ralston Creek, plus effective reclamation activity of the waste material piles provides the appropriate level of protection for this valuable drinking water resource. It is recognized that an inactive mine site and surface water contamination involves multiple state agencies that include the Water Quality Control Division (WQCD), DRMS, and the Radiological Division. As the draft Permit is prepared we strongly encourage and support close collaboration among responsible regulating agencies to ensure that all facets of the reclamation process are appropriately captured. For example what water quality standard(s) is DRMS using on establishing reclamation requirements, and what impact to the size and type of treatment will other remediation requirement have on the treatment system? We look forward to the opportunity to review a revised draft Permit for the Swartzwalder Mine wastewater treatment facility. Sincete y,. i es . Mc arthy, Manager egulatory and Environmental Compliance C: Thomas C. Mountfort, Denver Water Board Mr. Rick Jeschke, North Table Mountain WSD Dave Berry, DRMS