Laserfiche WebLink
Mr. Larry Perino <br />October 24, 1994 <br />Page No. 2 <br />in their letter of October 18, 1993 from Allen Sorenson. <br />Therefore, the Division considers the addition of bromide as an experiment not as a method of <br />determining compliance with the federal Clean Water Act or the Colorado Water Quality Control <br />Act. <br />What must also be considered is that seepage from around the American Tunnel bulkhead could <br />result in a continuous source of bromide into Cement Creek. Therefore, any tracer entering <br />Cement Creek at any location downstream of the American Tunnel may not be discernable from <br />that coming from the tunnel. Proposed monitoring is not adequate to detect the difference <br />between the two. <br />The Division will not recognize the absence of bromide as evidence that water from the <br />Sunnyside Mine is not reaching state waters. <br />3) Will the CDPHE through the CDPS permit renewals (which are in the drafting phase) make <br />allowances for bromide concentrations in the discharge before valve closures? The renewal <br />of the discharge permits will include any conditions that are necessary to insure that there will be <br />compliance with both numeric and narrative stream standards. Since it is fairly certain that there <br />will be seepage from the American Tunnel even after bulkhead installation, it is expected that the <br />permit for that discharge will require bromide monitoring. While it is not clear at this time what <br />numeric effluent limitation for bromide might be required, there is reason to continue Whole <br />Effluent Toxicity testing, with the inclusion of a specific WET limit. Sunnyside should request a <br />permit amendment to include the addition of bromide into the mine. <br />The Division will work with Sunnyside to address the addition of bromide and may use its <br />discretion curing an interiiii time period while the permit is being modified, provided <br />measures are taken to maintain the bromide concentrations at acceptable levels. However, <br />should there be any environmental impact from the addition of bromide, we will hold Sunnyside <br />accountable. <br />In summary we wish to provide the following: <br />a) With respect to Sunnyside's liability, the Division will hold Sunnyside responsible for insuring <br />that any tracer introduced into waters that may eventually reach surface waters of the State will <br />not result in a violation of numeric or narrative stream standards. This includes the prevention of <br />any discharge of toxic pollutants in toxic amounts. <br />b) The Division will hold Sunnyside responsible for controlling any point source discharge of <br />pollutants that are a result of its mining or plugging operations, regardless of whether or not such <br />discharges contain bromide tracer. However, the Division is still very interested in working with <br />Sunnyside to develop an agreement which allows the plugging to occur but also protects water <br />quality. <br />