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previously re: _ainec gas area <br /> r'emediatinC _oleo _ _ �r.d «ate. Se�GS cJ rG'. .r I <br /> treatment to 711 eC wale- base'.. <br /> Storm Water v "Traditicnal • NPDES <br /> It is our position that any paint source discharge of <br /> pollutants to waters of the United States, not directly <br /> associated with a precip-Ltacion or snow melt event, ( i . e , , <br /> dry weather flows) , must be permitted under a 'traditional " <br /> NPDES permit . :his means that any dry weatner flow from <br /> mine adits, seeps , frer.c:� drains and culverts are mine <br /> drainage or process wastewater, and cannot be covered by a <br /> storm water perm, it . A ' traditional " permit rust be written <br /> for these discharges including both technology based and <br /> water quality standard based requirements where applicable . <br /> (Water diverted around the mine without contacting any <br /> disturbed area, and does nor- mix with mine or process water <br /> may not require an NPDES permit . l Also dur_ng wet weather <br /> flows, most of the areas at an active Mine rust be covered <br /> by "traditional " NPDES requirements oecause storm water was <br /> included in develcpin3 :e effluent cu:del :nes reaulacions . <br /> Only wet weather surface runoff ercm some arcillary areas of <br /> active mines and inactive areas would fall under the storm <br /> water program. It is also important to note �nac these <br /> discharges can be covered by storm water requirements only <br /> if they do not combine " traditional " sources prior to <br /> discharge . Therefore, we recommend that the State combine <br /> both the storm water and traditional NPDES requirements into <br /> one permit at all active mines . There is too much overlap <br /> between storm water and dry Weather flow, avid active and <br /> inactive portions of the mire ro write separate permits We <br /> have attached the most :event version of the table <br /> (September 13 , 1993) describing the applicability of storm <br /> water at mining sites . <br /> 4 . Maintaining Rater Quality (financial Quarautee) <br /> It is of increasing importance to financially guarantee <br /> compliance with environmental performance at all phases of <br /> the mining operation including post -closure . This has been <br /> mentioned by both Region VIII and EPA Headgi:arters ' staff <br /> during discussions of environmental impact statements and <br /> NPDES permits for new mines Clearly, the public ' s <br /> financial costs of Summitville is also a strong argument <br /> financial guarantees , we chink that tnis is an area where <br /> the State, through ics mining program, has substantial <br /> regulatory ability. We wxi l ccncroue to loc'< into this <br /> issue on a federal level , but we pope tnat c^e State will be <br /> able to resolve this prot '. em through its authorities by <br /> requiring post - c-osure f nanc :a'i assurance . <br /> 4 <br />