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<br />III IIIIIIIIIIIII III <br />999 <br />TRBPPBR 1C11~11~G 1pC. <br />June 19, 1991 <br />CERTIFIED +YP458756359 <br />Ms. Kathryn Dolan <br />Colorado Dept. o[ Health <br />Water Quality Control Division <br />4210 East 11th Ave. <br />Denver, CO 80220-3716 <br />Dear Kathryn: <br />~~ t" ^a ~1" I~ <br />JUN 21 1991 <br />:V~ined ;_and <br />Reclamation Divisio~~ <br />Re: Trapper Mining Inc comments to draft NPDES permit for Trapper Mine -Permit Number CO- <br />0032115. <br />Following are Trapper's comments to the Division's drat NPDES permit for Trapper Mine. Additional <br />comments may follow as this document has not been thoroughly reviewed by all appropriate Trapper per- <br />sonnel. <br />1) Section IV.B. (Facility Description) -The last line on the first paragraph (page 3) should read -'ilte <br />effluent then goes directly to sedimentation pond 002 where it is discharged.' <br />Please find enclosed all seep flow volume data collected in the past year for site 005. Site 011 has not <br />been active since 1988. <br />On Table iV-1-Discharge points (page 4), the correct number o[ sediment ponds for site 002 (No <br />Name) is three. <br />2) Section V.B. (Performance History) (page 7) -Trapper requests the third sentence, second paragraph <br />read 'ilte use of a CO2 bubbler or other appropriate measure on the effluent may be required as a <br />Best Management Practice at the site whenever the variance is applied. Other appropriate measures <br />include the use of appropriate algicides, aquatic life, etc. as approved by the Division' <br />3) Section V1.2(a) (Terms and Conditions of Permit)(page 10) -Why are mine drainages used for <br />dewatering and/or having spoil springs not eligible for the storm event exemption condition under <br />active mining requirements) <br />4) Section VI.S(d) (Terms and Conditions of Permit) -Concerning the waiver requirements on page 13, <br />does this mean that if drainages requiring WET testing at Trapper Mine flow only doting one quarter <br />of any given year that four years of sampling are required to satisfy the waiver? <br />5) Section VI.C(1) (Additional Terms and Conditions)(page 14) - On May 31, 1990, Trapper Mining <br />Inc. submitted to the Division a revised Spill Prevention Control and Countermeasure (SPCC) Plan <br />for Trapper Mine. This revision updated all changes which have occurred on the mine site since our <br />original SPCC plan was submitted. Since this document is very current no changes or only very minor <br />changes may be needed to update this plan. Please find enclosed a copy of the 5/31/9() SPCC plan <br />submitted to the Division. <br />P.0. Box 187 Craig, Colorado 81626 (303) 824-4401 <br />