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RESPONSE TO DMG CONCERNS <br /> October 22, 1993 <br /> 1. Needs no reply. Proof of publication, mailing of notice and <br /> filing of application submitted to Allen Sorenson 10/19/93. <br /> 2 . Sunnyside Gold Corporation ("SGC") has requested a <br /> determination of the issue of whether or not SGC would <br /> continue to be responsible for discharge of water entering the <br /> American Tunnel from property belonging to other parties. The <br /> bulkhead plan proposed by SGC is intended to prevent water <br /> from flowing out of the Sunnyside Mine into the American <br /> Tunnel, with the expected result that American Tunnel portal <br /> outflows would be substantially reduced. Remaining portal <br /> outflows would be derived entirely from property owned by <br /> others. <br /> The Water Quality Control Division of the Colorado Department <br /> of Health ("WQCD") has determined that it would be <br /> inappropriate to grant SGC's request to move its permitted <br /> discharge point to the downstream end of the proposed bulkhead <br /> (see letter from Patricia Nelson dated 10/1/93) . Colorado <br /> Division of Mines and Geology ("DMG") has stated that WQCD's <br /> determination controls ("Since Rule 6.2 (1) (b) of the Mineral <br /> Rules and Regulations requires mine operators to be in <br /> compliance with WQCD Rules, it appears that any [Mined Land <br /> Reclamation] Board determination on continued American Tunnel <br /> flows would be a foregone conclusion. . . ") . Because DMG has <br /> determined that WQCD's rules control in this situation, it is <br /> not necessary for DMG to address the issue of continued <br /> discharge from the American Tunnel or the Sunnyside Mine in <br /> this permit revision, except to state as a general condition <br /> of the permit that the operator will comply with applicable <br /> statutes and valid WQCD regulations. <br /> 3 . SGC has requested that the requirement to collect four <br /> quarters of inventory data be reconsidered and that <br /> Poughkeepsie Gulch be dropped from the inventory survey <br /> requirement, because it is outside of the area that will be <br /> influenced by restoration of the groundwater regime to its <br /> pre-mining condition. DMG has declared that these requests <br /> "appear to be well founded. " If DMG is satisfied that the <br /> request to eliminate these requirements is well founded, as <br /> the text of its October 15 letter states, SGC requests that it <br /> eliminate the requirements. <br /> 4 . The purpose of the tracer study proposed by SGC is to <br /> determine whether water impounded by the American Tunnel <br /> Bulkhead is escaping around the bulkhead or making its way to <br /> the surface via previously undetected pathways. To that end, <br /> SGC has proposed monitoring Cement Creek to detect the <br /> presence of the bromide tracer. Theory predicts that the <br /> tracer should not be detected for 20 to 160 years, but that it <br />