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<br />and the mill itself as a new source because of the prestart <br />• up modifications in progress. However the same logic should <br />favor the defining of the discharge south of the old pond as <br />an er,isting source, as the reconstruction of the di4;e would <br />constitute the repair of an er.isting facility, not an <br />alteration. Every effort should be made to persuade the <br />State to adopt this position. The resumption of disposal in <br />the old pond should not alter this position, since the <br />permitted e>:isting source would be the seepage pond south of <br />the old pond, not the old pond itself. The reactivated old <br />pond would be included in the new source category and permit <br />for the new pond. <br />A number of operators have obtained "no discharge" permits <br />for new sources where no discharges are allowed other than <br />the excess between precipitation and evaporation, as is the <br />case with new source base and precious metals flotation <br />mills. The "no discharge" permit would allow the <br />intermittent discharge of excess rainfall and run off and <br />also provides a defense against action resulting from a <br />bypass or upset. The discharge allowed under the e>:cess <br />rainfall provision must meet the standards for new source <br />mine drainage as given in Table No.6 but with the more <br />stringent State standards for pH. The annual fee for "no <br />discharge" permit is $500 and monitoring would be required. <br />The monitoring requirements would be specified in the <br />• permit. <br />Table No.S: EPA Effluent Standards for New Source <br />Base and Precious Metal Mine Discharge <br />(1) (2) <br />TSS, mg/1 30.0 20.0 <br />Cu mg/1 0.30 0.15 <br />Zn, 1.5 0.75 <br />Pb, 0.6 0.3 <br />Hg, 0.002 0.001 <br />Cd, 0.10 0.05 <br />pH 6.0 - 9.0 <br />pH (State) 6.5 - 9.0 <br />(1): Maximum for 1 day <br />i2): 30 day average <br />The Clean Water Act and regulations require permitting of <br />storm water discharges far industrial plant areas (Group I), <br />which, in Sultan Mountain Mine's case, would consist of the <br />plant area east of the highway and possibly the repair shop <br />attached to the office on the west side of the road. However <br />because of the complexity of the problem, including the laclz <br />• -19- <br />