1994-03-23_HYDROLOGY - M1977378

• Permit No: M1977378
• IBM Index Class Name: HYDROLOGY
• Doc Date: 3/23/1994
• Doc Name: Water Quality Issues
• From: CDHE
• To: Sunnyside Gold Corp
• Permit Index Doc Type: Hydrology Report
• Media Type: D
• Archive: No

STATE OF COLORADO
COLORADO DEPARTMENT OF HEALTH
Dedicated to protecting and improving the health and //!— 1�7 7-3 7ff
environment of the people of Colorado ;
4300 Cherry Creek Dr.& Laboratory Building * •
Denver,Colorado 80222-1 S30 4210 L 11 th Avenue
Phone[phone] Denver,Colorado 80220-3716
[phone]
1/lViarh 23, 1994
Pabida A.NoW%MD,MPH
ExeoA a Dkector
Mr. Larry Perino / Mr. David C. Nacearti
Sunnyside Gold Corporation V Echo Bay Mines
P.O. Box 177 370 Seventeenth Street,Suite 4050
Silverton, CO 81433 Deaver, CO 80202
Re: Sunnyside Gold Corp., CDPS Permit No. CO-0027529
Water Quality Issues Related to the Installation of American and Terry Tunnel Bulkheads
Dear Mr. Perino and Mr, Naccarti;
The Colorado Mined Land Reclamation Board (MLRB)has approved Sunnyside Gold Corporation's request
to install bulkheads in the American and Terry tunnels and in several other connected inner tunnels. While
no additional regulatory authorization from the Water Quality Control Division is required for the Corporation
to proceed with the project, the MLRB's approval was granted contingent upon the Corporation satisfying
several commitments related to the protection of water quality. One of these commitments requires the
Corporation to notify the Water Quality Control Division if any significant change in water quality or quantity
is detected in seeps or other drainages surrounding the miite site following the placement of the bulkheads.
As explained to Sunnyside Gold in meetings and written correspondence,any such changes in water quality
or quantity that would constitute an increase is the loading of pollutants to,surface waters of the State must
be avoided. This applies not only to pollutants which would originate in or be carried through the mine
workings located inside Sunnyside's property boundaries, it also applies to pollutants which lie outside of the
Corporation's property but which have been made available for transport to surface waters as a result of the
Corporation's mining activities or plugging project.
More specifically, any new seeps, or existing seeps which exhibit as increase in metals loading after the
tunnels have been plugged, would be considered to be point source discharges that the Corporation would be
responsible for controlling. Considering the potential for creating numerous point sources - which would be
difficult to treat, it is important that the Corporation insure that it has the ability to detect new seeps or
changes in the pollutant loa '"a from old seers throughout the ent;re arm +hat rwght iw aff�c+ed.
Based upon the review of available documentation, it is not clear that the monitoring program that the
Corporation has developed will provide the information that will be required to make such determinations.
This is probably due to the Corporation focusing the program upon the detection of the tracer that it proposes
to introduce into the tunnels just before plugging. From conversations with the Corporation and its agents,
the reliance upon the detection of the tracer is apparently based upon the argument that unless the tracer is
detected, there has been no discharge from the mine, and therefore, the Corporation will not accept
responsibility for any increases in pollutant loadings-that might occur. -. -