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and regulations, this is how it would work. <br /> Parag,,,r ph 24. One commentor noted that the basic concept embodied in the CD of <br /> allowing SGC to remediate inactive mine sites throughout the Upper Animas Basin in return <br /> for terminating its permits for the Terry and American Tunnel discharges after sealing the <br /> Sunnyside Mine, is fundamentally flawed, because all of the inactive mine sites in the basin <br /> should already have permits which require the mine owners to perform such remediation <br /> work. While it is true that point source discharges including storm water occur at <br /> historically inactive mines, they are so numerous, scattered and variable, in terms of their <br /> water quality impacts and ownership patterns, that the Division has not been capable of <br /> pursuing a comprehensive strategy of issuing permits to such mines. Recently, through the <br /> development of the watershed approach to water quality management, it has become possible <br /> for the Division, in cooperation with the others, to conduct monitoring studies aimed at <br /> developing attainable water quality goals and targeting the most significant sources of mine <br /> drainage in watershed impacted by past mining activities. Such cooperative monitoring <br /> efforts in the Upper Animas Basin over the past 5 years provided the informational base <br /> which made this CD possible. <br /> The Division believes that a combination of approaches for addressing the impacts <br /> from inactive mines is appropriate and necessary. Each approach to improving water <br /> quality, whether it be a cooperative and voluntary effort conducted by remediating agencies, <br /> point source permitting by the WQCD, CERCLA cleanups and removal actions, or hybrid <br /> approaches such as contained in this CD, depends upon adequate watershed monitoring and <br /> assessment to enable limited resources to be well targeted. Watershed scale monitoring <br /> makes it possible to establish realistic water quality goals and standards, then to translate the <br /> goals into total maximum daily loads (or other specific limitations) so that proper resource <br /> allocation decisions can be made. The Division's Permitting strategy will be to address sites <br /> which are discharging significant (i.e. non-de minimus) pollutant loadings relative to the <br /> TMDL for the basin and where other approaches are not available for controlling the <br /> problem. <br /> Paragraph 24b. A commentor asks what BAT standards are. BAT limitations are <br /> technology based effluent limitations and standards based on effluent limitations and <br /> standards promulgated under Section 301 of the Clear Water Act or new source performance <br /> standards promulgated under Section 306 of the Clean Water Act. Some case by case <br /> effluent limitations are determined under Section 402 (a)(1) of the Clean Water Act. Specific <br /> effluent limitations have been promulgated for mining-related industrial categories including <br /> ore mining. The BAT limit for zinc in the ore mining industrial category is .75 milligrams <br /> per liter. <br /> Paragraph 25. A commentor asks if the State will be able to track the letter of credit <br /> expiration date, notice of alternate letter of credit and the 10-day period so the State can <br /> draw a draft of the letter of credit if necessary? The WQCD is currently developing specific <br /> procedures which will address this concern. <br /> 5 <br />