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• III IIIIIIIIIIIII III • RECEIVED Cripple Creek & Victor Gold Mining Company C A Joint Venture - Pikes Peak Mining Company, Manager NO11 O b ~T~ Operations OfFce Englewood OfFce Y 6AL P.O. Box 191, 2755 State Highway 67 P.O. Box 5078, 5251 DTC Parkwav S i 70 Ydor, CO 80860 Englewood, CO B~M~,iar' ~1Y0°oiplo c~ ~t7ot~y (719) 689-2977 • FAX (719) 689-3254 (303) 889-0700 • FAX (303) 889-0707 November 1. 1996 SENT BY FACSIMILE AND CERTIFIED RETURN RECEIPT REQUESTED P 289 926 295 Mr. Berhan Keffelew Environmental Protection Specialist Colorado Department of Natural Resources Division of Minerals and Geology Office of Mined land Reclamation 1313 Sherman Street, Room 215 Denver. Colorado 80203 Reference: Cresson Project; Permit M-80-244: Receipt of the Office of Mined Land Reclamation's Letter of October 7, 1996 Regarding Ground-Water. Dear Mr. Keffelew: The Cripple Creek & Victor Gold Mining Company ("CC&V") has received the letter from you listing numeric ground-water quality criteria. You stated to CC&V prior to our receipt of this letter that you believed numeric water quality criteria were necessary. CC&V responded that any ground-water criteria needed to take into account ambient water-quality as well as the variations in that quality. CC&V further noted that statistically-accurate representations of ambient water quality typically fit log-normal distributions and that our experience with these distributions suggested that the mean plus five or six sigma (standard deviations) had been found to begin to describe the natural range of these distributions. CC&V also discussed that ground- water criteria based on the existing water quality data for ground water could serve as a threshold that would, if reached, require (1) examination for a trend that would suggest the measured value was not spurious, and (2) investigation of possible sources if the threshold continued to be exceeded. CC&V does not feel that the proposed criteria reflect this approach. CC&V agrees that the closest one can assign a possible use to the waters of the Cripple Creek Mining District is to theorize that the water might be used, in part, for agriculture. Of course it is not a potential source of drinking water. Given the influence of sewage effluent for Victor and Cripple Creek, given the ambient mineralization of the District, given the grazing use of the surrounding lands, given the difficulty of completing a dependable well in the granodiorite, and given the prior appropriation of water in the entire Arkansas Valley, the water available for use is limited. As you know, water is supplied to the Victor and Cripple Creek areas from