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.,. ~ ,. <br />III IIIIIIIIIIIIIIII y4:~,. ~o,~ <br />• - ~~ t STATE OF COLORADO <br />Roy Ramer, Governor <br />Pani Shwayd¢r, Attmg Executive Dinttor <br />Dedicated to protecting and improving the lrealrh and environmem oldie people of Colorado <br />4700 Cherry Creek Dr. 5. Laboratory nuilding <br />Denver, Colorado 802227530 4210 E. 11th Averwe <br />Phone 1301) G92-2000 Dcnvcr, Colorado 8 02 2 0-3 71 G <br />1303) G91-4700 <br />RECEIVEQ <br />January 2G, 1995 <br />Mr. Berhan Keffelew <br />EnvironmenL~l Protection Specialist <br />Colorado Department of Natural Resources <br />Division of Minerals and Geology <br />1313 Sherman Strcet, Room 21~ <br />Denver, CO 80203 <br />JAN 31 1995 <br />Divisi~•1 Df Minerals 8 Geology <br />OF ~t0 <br />ti~ °+ <br />„c% ~B <br />.`~. <br />~ rHT6 ~ <br />Colorado Department <br />of Public Holrh <br />and Environment <br />Re: Cripple Creek and Victor Gold - CDPS Permit No. CO-0043648 (Permit Pending) <br />Surface Water Stream Standards and Potential for Acid Mine Drainage from Cresson Mine <br />Overburden <br />Dear Mr. Keffelew; <br />We are now in the process of reviewing comments received in response to the public-notice of the above-referenced <br />permit, and making appropriate revisions. One of the most critical issues involved in this permit is the classification <br />and associated standards for Arequa Gulch and Squaw Gulch, which will be drainages that may receive surface runoff' <br />or seepage Gom overburden disposal sites. <br />Ever since [he spring of 1994, when the Water Quality Control Division firs[ began discussing the potential discharges <br />associated with the Cresson Project with both the Division of Minerals and Geology and Cripple Creek and Victor <br />Gold, we have consistently maintained that Arequa Gulch is included in Segment 21 of the Upper Arkansas River <br />Basin. This also applies to Squaw Gulch. The drag discharge permit reflects this detemlina[ion. While it is possible <br />that the classification or standards for these two drainages may be changed in the futwe az a result of Water Quality <br />Convol Comaussion actions, we intend to apply the existing classifications and standards for Segment 21 N the <br />discharge permit until such WQCC action is taken. <br />With regard to the hardness that should be used in order to calculate hardness-dependent standards, this is discussed in <br />the draft permit rationale. While that discussion was originally limited to Arequa Gulch, we will use the same hardness <br />for Squaw Gulch based upon its geographic location and the lack of any site specific data. <br />With respect to the wnsideration of existing water quality conditions in Arequa Gulch ,there have been arguments on <br />both sides of the question of whether or not such conditions are a result of natural conditions, or az a result of past <br />mining activities. Hopefully, this can be resolved during any future commission hearings that might occur. Also, while <br />an aluminum standard is no[ currently in effect for Segment 21, it is possible for such a standard to be adopted if i[ <br />appears necessary. <br />