1994-10-27_HYDROLOGY - M1977378

• Permit No: M1977378
• IBM Index Class Name: HYDROLOGY
• Doc Date: 10/27/1994
• Doc Name: Review of Tracer Information
• From: CDPHE-WQCD
• To: Sunnyside Gold Corp
• Permit Index Doc Type: Hydrology Report
• Media Type: D
• Archive: No

� III I II'Il I II I'll III
999
_ 5TATE OF COLORADO
Roy Romer,Governor cam
Patricia A.Nolan,MD,MPH,Executive Director rn �/� 7-3 7l� r.Dedicated to protecting and improving the health and environment of the people of Colorado , l / y
•
4300 Cherry,Creek Dr.S. Laboratory Building
Denver,Colorado 80222-1530 4210 E.11th Avenue .►1876•
Phone[phone] Denver,Colorado 80220-3716
[phone] Colorado Department
of Public Health ]
October 24, 1994
and Environment
iltl Cl�-��.'.•.�
Mr. Larry Perino,Superintendent-Technical Services
,40 Sunnyside Gold Corporation
P.O. Box 177
Silverton,CO 81433 RECEIVED
Re: Sunnyside Gold Mining Corp. L-9ET 2 7 1994
CDPS Permit No.s CO-0027529 and CO-0035056
Review of Tracer Information
Division of Minerals&Geology
Dear Mr. Permo;
We have reviewed the information submitted with your letter of September 14, 1994 and respond to the
specific questions you ask as follows:
1) Does CDPHE endorse the concept of placing the bromide tracer in the Sunnyside Mine?
The Division's regulatory responsibility is to insure that any point source discharge of pollutants
is appropriately controlled. From one perspective,the documentation Sunnyside has provided
indicates that the addition of the tracer could enable the detection of some of the discharges which
might occur after the tunnel plugging operations are completed. On the other hand,it is possible
that some point source discharges might occur which will not be detected by the tracer. This is
further discussed in response number 2).
From a totally different perspective,the Division must also consider that the addition of the tracer
constitutes a change in the currently permitted discharge of pollutants,and could result in new or
different effluent limits or monitoring conditions being placed in the permit. This is further
discussed in response number 3).
The Water Quality Control Division neither endorses nor prohibits the introduction of
bromide,provided the discharge into state waters complies with state law.
2) Will the CDPHE recognize the absence of bromide in the monitoring program (after valve
closure) as evidence that water from the Sunnyside Mine is not reaching surface waters?
The documentation that has been provided does not show that the bromide tracer will be present
in all sites that have become potential sources of pollutants through Sumlyside's' mining
operations. It is possible that water seeping through such areas will become point source
discharges of pollutants,but will not contain any bromide. The use of bromide is experimental
and not a proven technology. It is yet to be determined if there will be adequate bromide in the
system so that detectable levels could be observed,or that the bromide will solubilize in the mine
water at detectable amounts. This determination is consistent with the statements made by DMG