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.t <br />~ ~ <br />STATE OF COLORADO <br />Roy Romer, Governor <br />Patti Shwayder, Acting Eeecutive Duector <br />Dedicated to protecting and improving the health and environment o(the people of Colorado <br />4300 Cherry Creek Dr. S. Laboratory Building <br />Denver, Colorado 80222-1530 4210 E. 11th Avenue <br />Phone 1303) 692-2000 Denver, Colorado 60220-3716 <br />(303) 691 4700 <br />January 26, 1995 <br />Mr. Berhan Keffelew <br />Environmental Protection Specialist <br />Colorado Department of Natural Resources <br />Division of Minerals and Geology <br />1313 Shemran S[ree[, Room 215 <br />Denier. CO 80203 <br />REDEI~ED <br />JAN 31 1995 <br />~ivist~ , of Minerals 6 Geology <br />~~ <br />OF' O <br />ti~ 9 <br />„r% \~~ <br />. 9J 14 <br />Colorado Deparunent <br />of Public Health <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 pemmit 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 from overburden disposal sites. <br />Ever since the spring of 1994, when the Water Quality Control Division lust 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 2 [ of the Upper Arkansas River <br />Basin. This also applies to Squaw Gulch. The draft discharge penni[ reflects [his de[ernlination. While it is possible <br />that the classification or standards for these two drainages may be cllallged in the future as a result of Water Quality <br />Control Commission actions, we intend to apply [he existing classifications and standards for Segment 2l in the <br />discharge pemmit ml[il such WQCC action is taken. <br />With regard [o the hardness t11a[ should be used m order to calculate hardtess-dependent standards, [his is discussed in <br />Ule draft permit rationale. While [Ila[ discussion was originally limited to Arequa Gulch, we will use the same hardness <br />for Squa+v Gulch based upon its geographic location alld the lack of any site specific data. <br />With respect [o the consideration of existing water qualig• conditions in Arequa Gulch ,there have been argtunents on <br />both sides of the question of +ahether or not such conditions are a result of natural conditions, or as a result of past <br />mining activities. Hopefully, [his can be resolved during am~ future commission hearings that might occur. Also, while <br />an alunlinunl standard is not currently in effect for Segment 21, it is possible for such a standard to be adopted if it <br />appears necessary. <br />