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t~(arch 22, 1995 Mr. John E. Hardaway page 2 In order to insure that any studies [he Di+iston requires CC&V to perform will be adequate to address the above conccros. and [hat CC&V is provided ++ith a more formal means to provide counter-proposals, the permit will be amended to incorporate a compliance schedule With specific actions that must be taken. This will be sent to public nonce for your review and comment. Permittine of the Roosevelt Tunnel Drainaee The data and associated information which you submitted in your letter of January l7, 1995, provided insight into the dynamics of the water quality characteristics of the Roosevelt Ttrnnel drainage. We have determined that it will be necessary [o include the Roosevelt Tunnel drainage in the existing permit for the Carlton Tunnel for the following reasons: I) at least portions of the Roosevelt Tunnel lie directly underneath properties owned by Cripple Creek and Victor Gold, or lie in undergroand zones that may intercept groundwater flow emanating from CC&V properties, or are connected to other undergound workings ++•hich may carry water originally emanating from CCRV propemes; 2) initial discussions with personnel from the State Division of Minerals and Geology indicate that, from a geological perspective. there is a significant potential for drainage from CC&V properties to enter the Roosevelt Ttmnel; 3) similar discussions +vith the DMG indicate that flow may originate in the Roosevelt Tunnel at a point further inside the mountain than what CC&V has indicated, and it is possible that some hydraulic connection may exist benveen the flows that eventually exit from the separate Carlton and Roosevelt Tunnels. 4) it is understood that CC&V is either the sole or principal operator maintaining the Roosevelt Tunnel, and that i[ is matn[aincd for the company's own purposes: ~) regazdless of its origin. the tunnel is point source discharge of water n hlch contains pollutants. In order to incorporate the Roosevelt Tunnel into the existing permit, +ve will include effluent limitations and monitoring conditions in the same permit amendment that will be processed for the Carlton Tunnel flow monitoring issue. Again, this will be sent to public notice, giving you another opportunity to submit written comments. Sinccrch•, 'f~='/i2 Patricia A. Nelson, P.E. Indus[nal Unit Chief Permits and Enforcement Section WATER QUALITY CONTROL DIVISION xc Rich Horstmann, WQCD fiery Soldano. WQCD George Moravec, WQCD Fred Dowsett, HMWMD Berhan Kcmcw, Division oCMinerals and Geology Roger Flynn Western Mining Action Group Local Hcahh Dcpanment USEPA Region VIII. Water Division CDPS Permit No. CO-0024562 Permit lilt