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l <br /> UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> REGION VIII <br /> 999 18th STREET SUITE 500 <br /> DENVER, COLORADO 80202 2466 <br /> 4-IDEC 2 2 RECEIVED <br /> Ref : 8114M-C ol DEr 2 7 1993 <br /> m- 17 7- S78 <br /> Dan Fraser, Chief WQCO, PERMOSSECTIdN <br /> Water Quality Bureau <br /> Montana Department of Kealth <br /> b Environmental Sciences <br /> Cogswell Building <br /> Helena, Montana 57620 <br /> Re : INPDES Permit Issues <br /> Hard Rock Mines <br /> Dear Mr, Fraser: <br /> This letter is in response to your request that EPA clarity <br /> its position on several key issues relating to the permitting of <br /> hard rock mines under Section 402 of the Clean Water Act (CwA) , <br /> The following paragraphs explain EPA Region VIIl ' s policy on t"e <br /> following issues: ( 1) point sources at hard rock mines; (1 a) <br /> historic mine adits; (l .b) ground water hydrologically connec�,ew <br /> to surface water; (2) regulation of historic mining areas; ( 3 , <br /> storm water vs . traditional NPDES; and (4) maintaining water <br /> quality after mining, <br /> I . Point Sourc2V at Hard Rock Mines <br /> l .a Historic Adits <br /> Mine adits are quite clearly point sources as defined <br /> Section 2 (14) of the CWA, 3 1362 (14 ) . Th= � '• <br /> defines the term "point source" as any discernable conf . : ­ . <br /> and discrete conveyance, including but not limited to at-;: <br /> pipe, ditch, channel, tunnel, conduit, well , discrete <br /> fissure, container, rolling stock, concentrated animal <br /> feeding operation, vessel or other floating craft from wn . <br /> pollutants are or may be discharged. Following this <br /> definition, discharges from mine adits at historic or ac� :,­ <br /> mines are point sources and are re ire <br /> etf luta�, ,�re bp—_, dj,g Zgg�to waters of ,n <br /> ni e S tes . However, as discussed in paragraph -Z-Mr--"- <br /> abandoned or long- term inactive mines have not been a r-cr <br /> priory for permitting . '—""" <br />