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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT, Water Quality Control Division <br />Rationale — Page 17, Permit No. C00036251 <br />RESPONSE 2: <br />The statement has been eliminated. As this section describes sources to the treatment facility, stating that the <br />source is water from the mine is adequate. <br />COMMENT 3: <br />Cotter plans to install a collection ditch along the toe of the mine waste dump and direct the water to a <br />collection area below the mine waste dump. Cotter plans to sample this water twice monthly as weather allows. <br />This is because at times in the winter, when the mine is not active, the county road that accesses the mine portal <br />area is impassable due to windblown snow. <br />RESPONSE 3: <br />The Division has added the following footnote to the permit limitations tables allowing for a winter monitoring <br />exemption: "Monitoring may be waived when the site is inaccessible for the entire monitoring period. The <br />permittee is responsible for documenting that the conditions at the site did not allow for access. " The Division <br />has reduced the monitoring requirement for Outfalls 001B, 002B and 002C to monthly, as this will be sufficient <br />monitoring for wastewater resulting from precipitation. Note that any collection area should be designed and <br />constructed to prevent impacts to groundwater to meet all necessary regulatory requirements. <br />Comments received from the Energy Minerals Law Center on behalf of Sheep Mountain Alliance, Colorado <br />Citizens Against Toxic Waste, and Environment Colorado. <br />These comments have been grouped by general topic. <br />COMMENT 4: Colorado Open Records Act (CORA). <br />Comments submitted may be updated based upon review of additional agency documents which have not yet <br />been gathered from WQCD field offices for review and release. CORA records do not reveal current <br />stormwater permits for JD -7 and JD -9 mines. <br />RESPONSE 4: <br />The WQCD has made several attempts to inform Sheep Mountain Alliance that the requested files were <br />available. E -mails and phone messages were delivered from 9/27/2010 through 10/4/2010, however, <br />representatives of Sheep Mountain Alliance have not responded. Additionally, the Department's Office of Legal <br />and Regional Affairs sent a letter (dated 10/01/2010) and additional email notifying the Sheep Mountain <br />Alliance that the files were ready for review. These contact attempts were made several weeks prior to the close <br />of the public comment period. <br />The previous permit combined stormwater and "process water" requirements into one permit. This permit <br />includes just process water discharge requirements. The permittee maintains stormwater permit coverage under <br />the previous individual permit until this reissued permit is effective. Cotter has now also obtained stormwater <br />permit coverage under a general permit, which will remain in effect once the coverage under the individual <br />permit ends the day before the effective date of this reissued permit. The stormwater discussion in the fact sheet <br />has been updated to include the general permit certifications in effect for the JD -7 and JD -9 Mines. <br />COMMENT 5: New permit, unpermitted point sources, other sources and impact of the proposed uranium <br />mill. <br />The additional point source discharge at the JD -7 and JD -9 mines require the issuance of a new permit, and <br />cannot be accomplished by the abbreviated process involved with a permit renewal. <br />The draft permit identified new outfalls; the problem requires additional scrutiny and immediate corrective <br />action. Similar updates should be expanded immediately to all mines on these segments. The JD -7 has <br />