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• ~ <br />Mr. Berhan Keffelew <br />Division of Minerals and Geology <br />]anuary 26, 1995 <br />Page No. 2 <br />The discharge permit has been designed in order to detect and control any point source discharges of process water. <br />The temp "process water" includes any type of drainage from waste rock areas, regardless of the quality of that <br />drainage. Whether or not the discharge meets water quality standards is not a factor in determining what is to be <br />pemtitted. Therefore, the standards are irrelevant in determining the need for a permit. Disposal of the material with a <br />high acid mine drainage potential will likely result in additional CDPS permit requirements. The Division of Minerals <br />and Geology should not factor the +Wter quality standard into their decision on whether the material should be capped s. <br />I am unaware of a site where it has been possible to predict the quality of acid mine drainage. It is strongly <br />recommended that the DMG require that the materials be capped in such a manner as to ensure that the conditions for <br />acid mine drainage are not allowed to form. Failure to do so may well result in perpetual treatment requirements at [he <br />site. <br />We are enclosing information +ve obtain from South Dakota. We suggest that the material be handled similarly. <br />Sincerely, <br />~Q -~~ <br />Patricia A. Nelson, P.E. <br />Industrial Uni[ Chief <br />Pemtits and Enforcement Section <br />WATER QUALITY CONTROL DIVISION <br />sc Demtis Anderson. WQCD <br />Gary Soldano. WQCD <br />Harry Posey, DMG <br />John Hardaway, Cripple Creek and Victor Gold <br />t,acal Health Dept. <br />USEPA. Region VIII. Water Division <br />CDPS permit nle, WQCD <br />CC~SfAND.N'Pb <br />