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~~~~~ ~ <br />WESTERN MINING ACTION PROJECT <br />1405 Arapahoe Ave. <br />Boulder, CO 80302 <br />(303)473-9618 <br />Fax (303) 440-8052 <br />wmap@igc.org <br />Via Fax - Hazdcopy to Follow by Mail <br />November 9, 1998 <br />Mr. Berhan Keffelew <br />Colorado Division of Minerals and Geology (DMG) <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Re: Cripple Creek & Victor Amendment #7 <br />Dear Mr. Keffelew: <br />III IIIIIIIIIIIIIIII <br />999 <br />RECEIVED <br />NOV 1 p 1998 <br />Division of Minerals & Geology <br />This letter follows up on our telephone conversation of this morning. 1 had called you <br />concerning information I received from individuals in Victor who stated that you were informing <br />CC&V and local residents that Citizens for Victor! (CFV) did not have a concem with the <br />potential for waste rock in Squaw Gulch to generate acid or metals. As I mentioned to you, such <br />a statement would be flatly incorrect. <br />It appeazs that you have misinterpreted CFV's concem for such generation in Arequa Gulch with <br />a lack of concern for Squaw Gulch. As noted in CFV's previous letters to [he DMG, while we <br />are of course concerned about ground and surface water impacts in Arequa Gulch, we share those <br />concerns in Squaw Gulch. For both azeas, we believe that the DMG/MLRB cannot permit an <br />operation that could generate acid or toxic-forming materials -and certainly not without a <br />complete geochemical analysis (currently lacking from CC&V submittals). <br />The fact that such releases would likely impact Arequa Gulch ground and/or surface waters faster <br />than such waters in Squaw Gulch due to the particulaz hydrological situation in each watershed <br />does oot mean that adverse impacts from acid ortoxic-forming materials in Squaw Gulch are <br />exempt from full protection by the DMG/MLRB. <br />As we discussed, due to the applicability of the Water Quality Control Commission's (WQCC's) <br />Interim Narrative Standard (INS) to all ground water that may be impacted by CC&V's activities, <br />the DMG/MLRB must set stringent ground water permit requirements. As noted in our October <br />2nd letter, since it is clear that "the most stringent" of the Table Value Standards for ground <br />water apply to this project, rather than "ambient" conditions as of January 31, 1994, CC&V's <br />Application as currently submitted fails to meet this test. <br />