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...- ~ . -~ TRAPPER DINING INC. III IIIIIIIIIIIIIIII 999 September 12, 1991 Ms. Pat Nelson Colorado Department of Health Water Quality Control Division 4210 East llth Ave. Denver, CO 80220.3716 Sip 1. ~ 1°31 ",I11V J ry - ~ l/ -~~.1 ~'_ (Iii ~ .~'.1~ I^'_ Dear Pat: Re: stormwater Permitting Requirements for Roads Outside Active Mining Facilities Concerning our 9/11/91 telephone conversation, Trapper Mining Inc. is responding to the EPA final regulation (55 FR 47990 -Nov 16, 1990) which addresses permit application requirements for stormwater discharge at industrial facilities. Trapper's major concern is the rule interpretation by the Water Quality Control Division when evaluating permitting requirements for access roads outside of an active industrial facility. Trapper was informed that the state may require stormwater permits for access roads outside of the active mining operation. Throughout Trapper Mine's permit area, there exists many miles of access light-use roads, traveled infrequently by pickup trucks and drill rigs, where the runoff from these roads does not go to established sedimentation ponds. The access roads of concern are all out- side of our active mining area and have no vehicle traffic carrying coal or other materials related to coal production. Additionally, little improvements have been made to these roads as no gravel, scoria or other mine waste material has been used for surfacing. The roads are primarily used for hunting access and by a local rancher to check livestock. In accordance with the EPA final regulation, access roads which are not within the active industrial facility are exempt from stormwater permitting requirements. On federal regis- ter page 48009 (vol 55 No 222) addressing final stormwater regulations the following statement is made "EPA would also like to clarify that it intends the language immediate access roads (including haul roads) to refer to roads which are exclusively or pri- marily dedicated for use by the industrial facility. EPA does not expect facilities to submit permit applications for discharges from public access roads such as state, county, or federal roads such as highways or BLM roads which happen to be used by the facility. Also some access roads are used to transport bulk samples of raw materials or products (such as prospecting samples for potential mines) in small scale prior to industrial production. EPA does not intend to require permit applications for access roads to operations which are not yet industrial activities." P.0. Box 187 Craig, Colorado 81626 (303) 824-4401