1994-03-23_HYDROLOGY - M1977378 (2)

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-E111111 IN III STATE OF COLOR999 ADQ COLOttADO DEPARTMENT Of HEALTH Ded sated to waNc6ng and inspr�n�the health and envimmw t o(dw people olCo= �]00 CM t',rNk Dr.S. UbwAfy OWWUV ✓ F aasn-1 s3o ,roe.,,t,,Avs�,ue /4- / � 77 -27S h,a+.Door 692.200o Denney CeWWO 80220a7116 OU Cw�n�r March 23, 1994 L/' A.Nohn MA aM Mr. Larry Perino �i Mr. David C. Naocarti Suaayside Goid Corporation Echo Bay Mines P.O. Box 177 370 Seventeenth Samar,Suite 4050 Silverton, CO 81433 Det;ver, CO 80Zt)3 Re; Sunnyslde Gold Corp., CDPS Permit No. CO-0027329 Water Quality Issues Related to the lutalladon of.'lmedean and Terry Tuaael Bulkheads Dear W. Perino and Mr. Naccard; The Colorado Mined Land Reclamation Board (ML.RB) hta approved Su=yside Gold Corporation's request to install bulkheads in the American and Terry tunnels and in several other connected inaee tunnels. While no additional regulatory anthoruuion from the Water Quality Control Division is required for the Corporation to prooeed with the project, the MLRB's approval wan granted contingent upon the Corporation satisfying several commitments related to the protection of water quality. One of these commitments xquim the Corporation to notify the Water Quality Comrol Division if any aisaiRcaat change in water quality or quantity is detactod in seeps or other drainages surrounding the mine site following the placement of the bulkheads. As explained to Sunnyside Ooid in Meetings and written correspondence, any such ohw4p in water quality Of quantity that would constitute an increase in the loading of poltutants to surface waters of the State must be avoided. Ilia applies not only to polluhnh which would originate in or be carried through the mine woddngs located tasida Sunnyside's property boundaries, it also applies to pollutants which Be outside of the Corporation's property but which have been made available for transport to surface waters as a result of tits Corporation's mining activities; or plugging Proms• More specifl%1lY, ANY new Seeps, or existing $eeps Which exhibit an increase in metals loading suer the tunnels have been plugged, would be considered to be point source discharges that the Corporation would be responsible for controlling. Conaidering the potential far C mdng numerous point sources •which would be difficult to treat, it is important that the Corporation iruure that it hae the ability to deteot new seeps or Changer in the pollt>W loading from old seeps throughout the entire are that might be allbcted. Based Upon the review of available documentatica, it is not clear that the monitoring program that the Corporation has developed will provide the information that will be required to make such datetminations. This is probably due to the Corporation focusing the program upon the detection of the treoer that it proposes to introduce into the tuande just before plugging. From convsrsadoae with rise Corporation and Ito agents, the rd ancae upon the detection of the tracer is apparently based upon the argumag that unless the tracer is detected, there has base no discharge from the mine, and therefore, the Corporation will not socspt responsibility for any foam aes in pollutant los4nSs that might oo=.