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