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Jim McArdle <br /> October 30, 1980 <br /> Page 5 <br /> In addition to the above issues discussed with Climax the DOW has <br /> certain reservation about two other items. <br /> Climax has for the past several years been in violation of their NPDES <br /> permit - up to and including this year. This subsequently puts them in <br /> violation of articles 6. 2 and 6. 3 of the mined land reclamation regulations <br /> and their present MLR permit. The question then becomes "why have <br /> these violations occurred and what is being done to correct them? " <br /> It is our understanding that Climax has underestimated the volume of <br /> water which needs to be treated, the degree to which water is con- <br /> taminated by heavy metals and other toxic substances, and the amount <br /> and degree of treatment necessary to fulfill the class one water standards <br /> assigned to Ten Mile Creek. <br /> We feel that a complete explanation of this issue is necessary. This is <br /> to include a discussion on the impacts and significance of unpermitted <br /> discharges, heavy metal concentrations and toxic substance contamination <br /> upon the fishery resource and water quality of Ten Mile Creek and <br /> Dillon Reservoir. <br /> It is our opinion that this amendment should not be given consideration <br /> for approval until all water quality issues are resolved. <br /> Last but not least, the wildlife section does not provide a "statement of <br /> impact of mining upon the local wildlife resource". For all practical <br /> purposes a species list only has been provided. Further elaboration <br /> of the impacts of mining and reclamation upon our wildlife resources <br /> is necessary. A discussion of habitat alterations appears appropriate. <br /> CGP;js <br /> cc: NW Region <br /> SE Region <br /> file <br /> Alex Chappell <br /> Tom Martin <br />