1996-06-12_ENFORCEMENT - M1977378

• Permit No: M1977378
• IBM Index Class Name: ENFORCEMENT
• Doc Date: 6/12/1996
• Doc Name: Sunnyside Gold Corp v. WQCD
• From: Dufford & Brown, P.C.
• To: Echo Bay Mines
• Media Type: D
• Archive: No

6. Comment: Page 15, Paragraph 9.c. and Page 22, Paragraph 14.g.: We are pleased
with the commitment to treat Cement Creek in order to mitigate short-term impacts
and to allow a "buffer" until the mine remedtation projects have adequate time to
improve water quality. However, we have some concerns regarding a lack of
specificity concerning Cement Creek treatment in the Consent Decree. We have three
main issues regarding Cement Creek treatment:
1) quantity of flow to be treated during which months,
Response: As stated in paragraph 9 (page 15) of the Consent Decree, the stream
diversion bringing Cement Creek into the treatment facility will be regulated in
volume so as to use the full capacity of the American Tunnel treatment facility.
Essentially all of the stream flow in the low flow months will be treated and the
equivalent stream flow lost to the treatment system due to mine sealing will be treated
during high flow.
Comment. 2) what will trigger the cessation of treatment of Cement Creek,
Response: Cement Creek will be treated during the time period that mitigation
projects are being completed by SGC. Following the completion of all "A" list
mitigation projects, SGC may reduce or eliminate the treatment of Cement Creek at
the American Tunnel treatment plant. SGC will notify the Division ten business days
prior to making changes in the quantity of flows of Cement Creek being treated
relative to their treatment plant capacity. In its notification to the Division SGC will
provide its analysis that water quality will be maintained at the reference point (A72)
with the decreased treatment of Cement Creek flows. The parties to the Consent
Decree have agreed to modify the language of paragraph 9c to reflect this.
Comment. 3) how long will SGC have to maintain a zinc concentration at the
reference point or below the 12-month moving average in order to be released from
treating Cement Creek;
Response: The Consent Decree requires specified actions on the part of SGC should
water quality deteriorate at the Reference Point. SGC may decrease or eliminate
treatment at Cement Creek following proper notification to the Division as discussed,
provided that the required mitigation projects have been completed.
Comment: 4) the response to exceedances of the monthly zinc average.
Response: Page 4a of Appendix A details the responses SGC will take in the event
that the monthly zinc average is exceeded. This section has been modified to clarify
the time frames required for submission of Work Plans for additional work projects
and construction of those projects if the A and B list projects already have been
completed. See response to Consent Decree comment 5.
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