HYDRO28434

• Permit No: M1980244
• IBM Index Class Name: Hydrology
• Doc Date: 2/27/1995
• Doc Name: CRIPPLE CREEK & VICTOR GOLD MINING CO CDPS PERMIT & AREQUA GULCH SEGMENTATION CLASSIFICATION & STAND
• From: CRIPPLE CREEK & VICTOR GOLD MINING CO
• To: WQCD
• Media Type: D
• Archive: No

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~~ ~~, Cripple Creek & Victor Gold Mining Company
~' a..r A Jomt VenNre -Pikes Peak M~m~o Comoanv Manager
~ Operatlona OIIIce Englewood Office gIe,~qp~
~C~' ~ ' P.O. Box 191, 2755 State N~~nway 67 5251 DTC Parkway. Swte 7ti CI.~C I V C V
~ ~ °~ - Victor, Coloratlo 80860 Coloratlo 80111 hjl=tit I V ~ V
[phone] • FAX [phone] [phone] • FAX (303) FEl3 277 ~99J
February 23, 1995 L
Ms. Patricia Nelson Division of minerals ts<Geolo9y
Industrial Unit Chief
Permits and Enforcement Section (WQCD-PE-B2)
Water Quality Control Division
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80222-1530
Re: Cripple Creek & Victor old Mining, Co~anX CDPS Permit and Areuua Gulch
Seementation. Classification. and Standards
Dear Ms. Nelson:
Thank you for sending a copy of your January 26, 1995 letter to Berhan Keffelew of the Office
of Mined Land Reclamation. This letter addresses issues raised in your letter.
The letter stated that the Division has consistently maintained that Arequa Gulch is included in
Segment 21 of the Upper Arkansas River Basin. As you know, Cripple Creek & Victor Gold
Mining Company disagrees with this position regazding inclusion in Segment 21. In order to
attempt to resolve the issue, as well as other issues associated with water-quality standards, we
have asked the Colorado Water Quality Control Commission to include consideration of a new
segment for Arequa Gulch (and other currently unclassified drainages if necessary) at its August
l4, 1995 hearing on the Arkansas River Basin. The hearing notice for this hearing will go into
the Commission packets on March 29, 1945. While we undoubtedly will initially disagree over
some aspects of the proposal, we should be able to reach agreement. We would like to meet
with you and Dennis Anderson to discuss this matter.
With respect to the hardness issue, we take the position that the metals equations published in
the Commission's regulations are hardness-based and do not contain an upper limit for hardness.
No upper limit was discussed when these regulations were adopted. We believe the Division
is without legal authority to impose a limit such the de facto limit of 400 mg/1 that has arisen
in the draft permit. This issue will affect the development of site-specific ambient-based metals
standards in Arequa Gulch because the hardness exceeds 400 mg/1. Thus, if a 400 mg/I limit
is used in a discharge permit, a similar limit must be used in comparing metals values against
Table Value Standards values in the development of site specific standards and the instream
buffering capacity must be accommodated.
Concerning existing water-quality conditions in Arequa Gulch, we are presently gathering water-
quality data and developing proposed site-specific ambient-based standards and are addressing