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4 <br /> Denver, CO 80202-2466 <br /> Permit for Mitiadtjan Projects CO0044768 <br /> 2. The draft permit for the Sunnyside Gold Corporation (SGC) Mine Remediation Projects lacks <br /> specific conditions for environmental control. The draft permit only requires full <br /> implementation of the Mine Remediation Plan (MRP), however criteria have not been <br /> established for the contents of an MRP, As written, the permit does not contain necessary <br /> technology based controls, as required by Federal regulations. <br /> At a minimum, the draft permit for SGC must include specific requirements for all MRPs.We <br /> feel that these requirements should be similar to the those for the storm water management <br /> plans (SWMPs) for inactive mines as drafted by CDPHE for the draft General Permit for <br /> Stormwater Discharge Associated with Metal Mining Operations and Mine-Waste Rsmediation <br /> (Permit Number COR-040000. Parts I.C.t - I.C.61. A particular emphasis should be placed <br /> erosion control during and after (revegetation) the remediation project. <br /> Additional SWMP requirements related to plan preparation, implementation, retention, <br /> submittal, review and approval by COPHE, plan changes, non-stormwater discharges, <br /> inspections SWMP ava ablift—and-pmcedures for covering additional projects must also be <br /> added to the permit. For those projects where edits are present, requirements related to adit <br /> ,closure or treatment should be added to the permit to address flow other than storm water. <br /> The MRPs wig need to be modified to be in compliance with these permit conditions. Review <br /> and approval of the work plans should be through the permit process rather than the consent <br /> decree. <br /> Amei can Tunnel Permit 0 _ 2752 <br /> 3. After reviewing data from the existing facility, EPA believes that there is a reasonable potential <br /> for toxicity at this site under present conditions. EPA understands that once treatment Of <br /> Cement Creek begins and the tunnel discharges lessen. there is likely to be an overall reduction <br /> in toxicity of Cement Creek below the facility. However, until it can be shown that there has <br /> been a substantial reduction in toxicity of Cement Creek downstream of the tunnel discharge <br /> (over present conditions) Whole Effluent Toxicity (WET) monitoring and limits should apply to <br /> the Discharge. <br /> Terry Tunnel Permit C0-0036056 <br /> 4. The Terry Tunnel discharge permit should contain a schedule for termination of the discharge. <br /> Emergency discharges and those related to maintenance should be addressed through standard <br /> language contained in the permit. <br /> TOTAL P.005 <br />