1995-05-16_REVISION - M1977378 (2)

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05/16/1995 13:02 303-782-0390 CDH WQCD WQCC PAGE 06 Mr.William Goodbard May 12, I995 Page No. 5 The Division does not understand the calculation methodology outlined in your proposal. We would appreciate your clarification on this at the May 17 meeting. It seems that the reference point loading should be equal to the calculated loading at the reference point minus the loading of any adverse impacts.(it is suggested that the term "adverse impact"be defined in the agreement.) The Division does not we the reference point as a goal or an indicator. This value is a baseline which will trigger required actions if exceeded. Estimated Timing The Division is not comfortable with committing to a five year time period from when the plug is placed at the property line to permit release. The Division will want to see the mine pool stabilized prior to permit release and have a good baseline of information which shows that the 520 ug/l is met and will continue to be met prior to allowing the permit to terminate. The inclusion of the alkaline waters may push the decision point somewhat fiudter into the future. It is our understanding the DMG permit requires monitoring after equilbruim and is not tied to the date that the plug is closed at the property line. Conditions for final Pe nit Release Items 1 and 7 do not necessarily agree. Item one says that the mine pool has reached equilibrium plus 2 years while ittm seven states that five years has elapsed since the valve was closed at the property line. While it is possible that these two could agree,it is also possible that equilibrium may not be reached in flute years. If the mine takes 10 Years to reach equilibrium, The time period for release could be 12 years after closing the plug at the property line. The conditions outlined for permit release do not state that the quality of the Animas is acceptable. it is very important to the Division that any release from any additional requirements be contingent on the quality of the Animas. Dam RM. There was an item which we discussed previously but on which your proposal was silent on, this is the need for public involvement. It 18 very important that the public which will be affected by the activities of SGC have the opperhmity to review and ceUmmeat on this agreement. The Division will not enter into an agr eca ent which is opposed by the gencral public. The Division will insist that Echo Bayt commit itself to compliance with the agreement and the NPDES permits. and a requirement that Echo Bay Mining is party to the aunt Long Term Liability.There were savaral statcamb in the proposal which deal with the release of long term liability. These matters will need to be dealt with individually. In some cases the Division may not have the authority to release SGC firm liability,in others the amount of release that we feel comfortable with is directly related to other conditions,of the agreement. These issues will need to be dealt with during the drafting of an agreement.