2011-08-18_HYDROLOGY - M1977306 - Laserfiche WebLink

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Radionuclide Standards Parameter Picocuries per Liter Americium 241* 0.15 Cesium 134 80 Plutonium 239, and 240* 0.15 Radium 226 and 228* 5 Strontium 90* 8 Thorium 230 and 232* 60 Tritium 20,000 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT, Water Quality Control Division Rationale — Page 25, Permit No. C00036251 maintained at the lowest practical level. In no case shall radioactive materials in surface waters be increased by any cause attributable to municipal, industrial, or agricultural practices or discharges to as to exceed the following levels, unless alternative site - specific standards have been adopted pursuant to subsection (4) below: Regulation 31.11(2) (underline emphasis added). The draft permit documents do not appear to take into consideration the applicable narrative standard that "the radioactive materials in surface waters shall be maintained at the lowest practical level." The Division should conduct a review of its analysis and make changes as necessary to account for this requirement, including further limiting radioactive constituents such as uranium. RESPONSE 12: The Division does not regulate the disposal of sludge from mines, however, the Fact Sheet points out that waste sludge removed from the treatment facilities is transported to the Cotter Corporation Canon City uranium milling facility for disposal in the tailings impoundments at that location. The Cotter Canyon City Mill Disposal site is a licensed radioactive materials disposal site under the jurisdiction of the Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment. The current limitations do take into account all radionuclide parameters from the table shown at Regulation 31.11(2), also at Table A -2 of the WQA. Most of the radionuclides listed are man -made and not expected to be present at the mine site. Those pollutants of concern that are expected to be seen in the mine discharge are presented in Section V of the WQA and addressed in the permit. COMMENT 13: Antidegradation Review is required The WQA asserts that antidegradation review will not be conducted based on determinations regarding Stream Segment COGULDO3a (tributary streams) which became effective in 2000, when the uranium industry was in the second decade of inactivity. This determination is stale and no longer reflects the circumstances. Now, a plan to revive the uranium mining and milling industry exists, which has already presented new and /or increased impacts on the tributary system. Several new mines have been permitted, initial operations conducted, and many mines put on standby status in anticipation of approval /construction of the proposed Pifion Ridge Mill. The Denison Mill near White Mesa has once again begun processing of locally mined ores to supplement its revenue stream from processing and disposing of "alternate feed stocks." The WQA states that "an antidegradation review is required for this segment if new or increased impacts are found to occur." WQA Appendix A at 21. The increased level of mining and milling activity provides both new and increased impacts. In 2000, there were no active uranium mills on these stream segments and the existing mill site at Slick Rock on the Dolores River had undergone remediation and was placed in long term care status. No mill has ever operated on the East Paradox Creek stream segment. A current anti - degradation analysis is necessary for both stream segments analyzed in the WQA. Importantly, the WQA analysis relies on erroneous information to