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w <br />. ~ ~ III IIIIIIIIIIIII III <br />STATE OF COLORADO <br />Roy Romer, Governor <br />Patti Shwayder, Executive Director <br />Dedicated to protecting and improving the health and environment o! the people o(Colorado _ <br />r_ <br />4300 Cherry Creek Dr. S. Laboratory and Radiation Services Division =I~~ L - <br />Denver, Colorado 80246-1530 8100 Lowry Blvd. <br />Phone (303) 692-2000 Denver CO 80220-6928 <br />Located in Glendale, Colorado 1303) 692-3090 <br />http://www.cdphe.srate. co.us <br />October 21, 1997 <br />Mr. Berhan Keffelew <br />Colorado Department of Natural Resources <br />Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />uCT 2 3 199i <br />...,,,,~~~:,~ ,. ucc,.__. <br />OF. ~~20 <br />0.~ <br />„~~ ~~ <br />. ~ . <br />~ r876 ~ <br />Colorado Depaztment <br />of public Health <br />and Environment <br />Re: Cresson Project, DMG Permit No. M-80-244, CDPS Permit No. CO-0043648 <br />Use of Pond #6 Water for Irrigation <br />Dear Mr. Keffelew; <br />This letter is in relation to your request for comments on Cripple Creek and Victor Gold's <br />(CC&V) use of Pond #6 water for the purpose of irrigation of reclamation areas. <br />In general, the Water Quality Control Division has no objections to the Division of Minerals <br />and Geology's approval of the use of Pond #6 water for the purpose of irrigation, provided <br />that such irrigation operations are carried out in a manner that avoids discharges to surface <br />waters of the State. It is important that there be assurance that not only will direct surface <br />runoff of the water be avoided during the initial irrigation activities, but that pollutants <br />contained within the water will not migrate through the soils and underlying rock, and <br />subsequently re-surface in State waters. <br />In the case of the Pond #6 water, it appears that specific pollutants that could be of concern are <br />nitrates, sulfates, manganese and possibly silver. While there are no surface water standards <br />for nitrates or sulfates for Arequa Gulch or Cripple Creek, any re-surfacing of nitrates or <br />sulfates could complicate efforts to utilize nitrate as a tracer indicating the presence of mine <br />drainage, or in any Total Maximum Daily Load analyses for downstream segments should <br />those type of analyses become necessary in the future. With respect to manganese and silver, <br />the concentrations of these two metals are above stream standards. If the metals released to <br />the environment during the irrigation process were to eventually migrate back into the surface <br />hydrologic system, it is possible that they coud contribute to or directly cause a violation of <br />stream standards. <br />