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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT, Water Quality Control Division <br />Rationale — Page 24, Permit No. C00036251 <br />standard for iron was reported as 0.3 mg/L. Hydrological Reportl3 at 30 -31. Both the WQA analysis and the <br />permit must provide information, analysis, and the necessary controls on iron discharges to ensure compliance <br />with water quality standards. <br />RESPONSE 11: <br />Stream segment COGULDO3a is not listed on the Colorado's 303(d) list of water quality impacted streams, and <br />this list was just updated as of April 2010. If there are water quality data showing impairment of state waters, <br />they need to be sent to the Environmental Data Unit of the Division. If the segment were 303(d) listed, and a <br />TMDL was to be written, the likely outcome is that the WQS would be granted to all discharges on the segment. <br />The currently proposed numeric effluent limitations for JD -7 and JD -9 mines are either the WQS or the more <br />stringent federal ELG, which if complied with, will not on its own cause any exceedances of water quality <br />standards. When the TMDL for the Dolores River is completed, consideration will likely be given as to <br />whether or not the mines need waste load allocations for iron. However, as seen in the following paragraph, it <br />is unlikely that these discharges travel directly to the Dolores River. <br />The Dolores River within stream segment COGULD02, is included on the 303(d) list of water quality impacted <br />streams for total recoverable iron; however, as concluded in the WQA and Factsheet, the discharge is not <br />expected to reach the Dolores River. A maximum flow of 0.2 MGD of wastewater is discharged from the JD -7 <br />WWTF into an unnamed tributary which would then need to travel approximately 12.5 miles to the Dolores <br />River. A maximum of 0.3 MGD of wastewater is discharged from the JD -9 WWTF into an unnamed tributary <br />to Fawn Springs, which would then need to travel approximately 10.5 miles to reach the Dolores River. It is <br />very unlikely that the discharge from these mines will make it to the Dolores River, flowing over 10 miles on a <br />zero low flow stream. <br />The groundwater discharges from the mine are under the jurisdiction of DRMS. When a discharge is to <br />groundwater directly in the alluvial material of a river, the Division will typically determine that it is a surface <br />water discharge. Although the groundwater may have been deemed tributary to the Dolores, the discharge is <br />not in the direct alluvium of the Dolores River and therefore the groundwater discharge is considered to be <br />solely a groundwater discharge. <br />COMMENT 12: Radionuclides <br />Because radionuclides are involved with these mines, the disposal of the treatment residues poses a serious <br />problem which is not addressed in the permit. The current analysis fails to address this problem, which is also a <br />live problem faced at Cotter's Schwartzwalder mine. The purported plan at the Whirlwind Mine is to dump the <br />treatment residues back into the mine workings. Dumping radioactive treatment wastes back into the mine has <br />no basis in law, may create additional contamination problems, and cannot be considered "best available <br />technology" where specialized facilities exist to dispose of these radioactive and toxic wastes. <br />Narrative Standards require minimize levels of radionuclides, but are not included in the permit. The existing <br />permit applies a uranium standard of 30 micrograms per liter as a discharge limit. However, the Water Quality <br />Control Commission recently approved changes to the basic standards for surface water (Regulation 31) <br />adjusting the uranium standard from 30 micrograms per liter to 16.8 micrograms per liter. While the new <br />Regulation 31 changes will not go into effect for a short period of a few months, the Division should <br />incorporate the new standard into the permit. Such an inclusion is justified under the site - specific circumstances <br />including the direct threat to water supplied by downgradient domestic and agricultural water wells. Further, <br />with respect to the uranium discharge limit, the WQA appears to have an incomplete listing of the applicable <br />narrative water quality standards. Specifically, the WQA does not account for the narrative standard set forth in <br />Regulation 31 for radionuclides. Regulation 31 states: The radioactive materials in surface waters shall be <br />