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.r <br /> Mr. Bill Goodhard and Mr. Naccarati <br /> October 1, 1993 <br /> Page No. 2 <br /> As discussed in our meeting in June, the Division is willing to work with Sunnyside to come to an <br /> arrangement which provides for the possibility to inactivate the permit(s)at some point in the future. The <br /> Division's obligation is to ensure that the uses and quality of the streams in the area maintain their <br /> quality. The Division acknowledges that Cement Creek is of not good quality,however the Animas River <br /> is of good quality. The Division must ensure that activities at the mine do not result in a degradation of <br /> this quality. The Division's overriding goal is to protect the beneficial uses of state waters. We can not <br /> allow the discharge from this site to impact those standards and beneficial uses. Therefore, this site will <br /> not be allowed to inactivate its CDPS permit unless either there are no discharges to state waters or it is <br /> determined that the discharges will not impact the standards without treatment as determined by <br /> comparison with water quality standards based effluent limitations where appropriate. <br /> As discussed in our June 17 meeting, the Division is willing to work with Sunnyside to determine a <br /> method of addressing our concerns as well as Sunnyside's desire to inactivate the permit. It is felt that <br /> this could must likely be done by looking at the site as if it were under a bubble and establishing a point <br /> of compliance which is just outside the bubble. This would allow Sunnyside the flexibility to take the <br /> measures inside the bubble so that standards are met at the compliance point. The bubble concept would <br /> have to be part of a CDPS permit. As discussed in the June meeting, standards would be set at a point <br /> of compliance. The Division would need to ensure that the standards are being met and that the site has <br /> stabilized before the permit could be inactivated. Should Sunnyside wish to pursue the bubble concept, <br /> it is suggested that we begin discussions on the elements of such a plan. <br /> Please contact me with any questions or if additional clarification is needed. The Division would <br /> appreciate an update on the current plans for the site. <br /> Sincerely, <br /> Patricia A. Nelson, P.E. <br /> Industrial Unit Chief <br /> Permits and Enforcement Section <br /> WATER QUALITY CONTROL DIVISION <br /> cc- Jim Horn, Field Support Section, WQCD <br /> Local Health Department <br /> Amelia Whiting, Attorney General's Office <br /> Allen Sorenson, Division of Minerals and Geology, MLRB Permit NO. M-77-379 <br /> Mr. William C:,Robb, Welborn Dufford Brown&Tooley <br /> Melanie Pallm.4EPA <br /> Dana Allen, EPA <br /> \D0CUMENT\LETTERS\1NACT1 VATE.SGC <br />