Fact      Sheet

NPDES Permit Number: AKG-37-0000
Date:     April 21, 2005
Contact:   Cindi Godsey
        Alaska Operations Office/Anchorage
        (907) 271-6561 or (800) 781-0983 (in Alaska only)
        godsey.cindi@epa.gov

       The U.S. Environmental Protection Agency (EPA)
     Plans To Re-issue A Wastewater Discharge Permit To:

                Alaska Mechanical Placer Miners

                This will also serve as a notice of a
            FINDING OF NO SIGNIFICANT IMPACT (FNSI),

                          and

               NOTICE OF STATE CERTIFICATION
                          and
                  provide information on the
            ALASKA COASTAL MANAGEMENT PROGRAM

EPA Proposes NPDES Permit Re-issuance.
EPA proposes to re-issue a National Pollutant Discharge Elimination System (NPDES)
General Permit to Alaska Mechanical Placer Miners for gold placer mining operations in
Alaska. The draft permit sets conditions on the discharge - or release - of pollutants
from operations into waters of the United States. EPA's goal is to have this permit
become effective as the 2000 GP expires. If this occurs then EPA is proposing to
automatically cover anyone who submitted a timely NOI for reapplication under the
2000 GP. If the GP does not go into effect in October, EPA would make a
determination at the time of re-issuance whether a new NOI would be necessary for
coverage.

This Fact Sheet includes:

    $$ information on public comment, public hearing, and appeal procedures
    * a description of the industry
    * a description of proposed effluent limitations, monitoring requirements, and
        other conditions.

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Finding of No Significant Impact (FNSI)

      In compliance with EPA headquarter guidance for re-issued NPDES permits, the
      EPA Region 10 NEPA Compliance Program has evaluated the proposed
      changes to the NPDES permit and balanced the need to re-evaluate the NEPA
      analysis. EPA Region 10 has determined that the previous Environmental
      Assessment for placer Mining developed in December 1993 does not need to be
      amended with a new NEPA analysis, as the draft permit conditions for the re-
      issued NPDES permit are not significantly different from the previous permit.

The State of Alaska certification.

      The Alaska Department of Environmental Conservation (ADEC) has provided a
      draft certification of this NPDES general permit under section 401 of the Clean
      Water Act.  This document may be found in Appendix A.

Consistency Determination

      This GP was previously found consistent on June 23, 2000. On January 13,
      2005, EPA requested information on the Alaska Coastal Management Program
      (ACMP) review. On March 2, 2005, the Department of Natural Resources/Office
      of Project Management and Permitting (OPMP) sent a response letter.  In its
      response, OPMP stated that with the minor proposed changes to the GP, a new
      ACMP review is not required.

EPA invites comments on the draft permit and FNSI.

      EPA will consider all substantive comments before issuing a final permit.  Those
      wishing to comment on the draft permit, FNSI, or request a public hearing may
      do so in writing by the public notice expiration date. Please submit comments to
      USEPA-Region 10, 1200 Sixth Avenue, OWW-130, Seattle, Washington 98101.
      Comments may be submitted by e-mail to godsey.cindi@epa.gov or faxed to
      (206) 553-0165.  All comments should include name, address, phone number, a
      concise statement of basis for the comment and relevant facts upon which it  is
      based. A request for public hearing must state the nature of the issues to be
      raised as well as the requester's name, address and telephone number.

      Persons wishing to comment on State Certification should submit written
      comments by the public notice expiration date to Luke Boles at the Alaska
      Department of Environmental Conservation, 610 University Avenue, Fairbanks,
      Alaska 99709. Mr.  Boles may be reached by phone at (907) 451-2142 or by e-
      mail at boles.luke@dec.state.ak.us

      For information on the ACMP review process,  please contact Ms Amanda Henry
      at DNR/OPMP, 550 W. 7th Avenue, Suite 1660, Anchorage, AK, 99501  or at
      (907) 269-7468.
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      A General Permit follows rulemaking procedures so EPA's issuance and
      promulgation activities must be conducted in accordance with the Administrative
      Procedure Act (APA). The modifications in this general permit will become
      effective 30 days after publication of the final general permit in the Federal
      Register according to Section 553(d) of the APA.  Anyone wishing to appeal this
      general permit must do so in court according to 40 CFR §124.19. Interested
      persons may challenge the modifications, within 120 days of issuance, in the
      Circuit Court of Appeals of the United States under Section 509(b)(1) of the Act.

Documents are available for review.

      The draft NPDES permit and fact sheet can be reviewed at EPA's Regional
      Office in Seattle between 8:30 a.m. and 4:00 p.m., Monday through  Friday. This
      material is also available for inspection and copying at the following places in
      Alaska:

            USEPA Alaska Operations Office
            Federal Building, Room 537
            222 West 7th Avenue
            Anchorage, Alaska 99513-7588
            Telephone: (800) 781-0983 (Within Alaska)

            USEPA Alaska Operations Office
            410 Willoughby Avenue, Suite 100
            Juneau, Alaska 99801
            Telephone: (907)586-7619

            ADEC Watershed Development Program
            Air and Water Quality Division
            610 University Avenue
            Fairbanks, AK 99709
            Telephone: (907)451-2142

Copies of the draft permit and fact sheet can be found on the EPA,  Region 10 website
at http://www.epa.gov/r10earth/waterpermits.htm (click on draft permits, then Alaska).
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                          TABLE OF CONTENTS

LIST OF ACRONYMS 	 5

I.   GENERAL PERMITS	 6
    A.   Permit Coverage	 6
    B.   Limitations on Coverage 	7
    C.   Prohibitions	 7
    D.   Individual Permits 	 8
    E.   New Source Notification Requirements	8

II.   REGULATORY HISTORY OF PLACER MINING IN ALASKA	 9

III.  INDUSTRY DESCRIPTION	 11

IV.  RECEIVING WATER	 12

V.   EFFLUENT LIMITATIONS	 13
    A.   No Discharge Facilities:	 13
    B.   Discharging Facilities	 13

VI.  Monitoring Requirements	 15
    A.   No Discharge Facilities  	 16
    B.   Discharging Facilities	 16

VII. BEST MANAGEMENT PRACTICES (BMPs)	 16

VIII. OTHER PERMIT CONDITIONS  	 19
    A.   Oil Spill Requirements	 19
    B.   Endangered Species Act (ESA) 	 19
    C.   Essential Fish Habitat (EFH)	 19
    D.   Consistency Determination	 20
    E.   State Certification 	 20
    F.   Permit Expiration	 20

APPENDIX A-DRAFT §401 CERTIFICATION	 21

APPENDIX B -- BASIS FOR EFFLUENT LIMITATIONS  	 24

APPENDIX C --  REFERENCES	 27
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                           LIST OF ACRONYMS

AAC     Alaska Administrative Code
ACMP    Alaska Coastal Management Program
ADEC    Alaska Department of Environmental Conservation
ADNR    Alaska Department of Natural Resources
AR      Annual Report
AWQS    Alaska Water Quality Standard
BAT/BCT Best Available Technology/Best Conventional Technology
BMP     Best Management Practices
BPJ      Best Professional Judgement
CFR     Code of Federal Regulations
CSU     Conservation System Unit
CWA     Clean Water Act
DNR     Department of Natural Resources
EFH     Essential Fish Habitat
EPA     Environmental Protection Agency
ESA     Endangered Species Act
FR      Federal Register
GPM     gallons per minute
MCL     Maximum Contaminant Level
NMFS    National Marine Fisheries Service
NOI      Notice of Intent
NPDES   National Pollutant Discharge  Elimination System
NSPS    New Source Performance Standards
NTU     Nephelometric Turbidity Unit
OHMP    Office of Habitat Management and Permitting
OPMP    Office of Project Management and Permitting
SPCC    Spill Prevention Control and Countermeasure
USFWS  United States Fish & Wildlife  Service
USGS    United States Geological Survey
AKG-37-0000
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I.    GENERAL PERMITS

     A.   Permit Coverage

          1.    Section 301 (a) of the Clean Water Act (CWA) provides that the
               discharge of pollutants is unlawful except in accordance with a National
               Pollutant Discharge Elimination System (NPDES) permit.  Although
               such permits are usually issued to individual dischargers,  EPA's
               regulations also authorize the issuance of "general permits" to
               categories of discharges [40 CFR 122.28] when a number of point
               sources are:

               a.   Located within the same geographic area and warrant similar
                   pollution control measures;

               b.   Involve  the same or substantially similar types of operations;

               c.   Discharge the same types of wastes;

               d.   Require the same effluent limitations or operating conditions;

               e.   Require the same or similar monitoring requirements; and

               f.    In the opinion of the Director, are more appropriately controlled
                   under a general permit than under individual permits.

          2.    Like individual permits, a violation of a condition contained in a general
               permit constitutes a violation of the Act and subjects the owner or
               operator of the permitted facility to the penalties specified in Section
               309 of the Act.

          3.    A Notice of Intent (NOI) to be covered under this General Permit (GP)
               is required [40 CFR 122.28(b)(2)(i)] for facilities that did not submit an
               NOI under the expiring permit.  The requirements are outlined in Permit
               Part I.A. and  an NOI information sheet is Appendix A of the GP.

          4.    This GP will expire five (5) years from the date of effective date.  40
               CFR 122.28(b)(1) allows a general permit to be administered according
               to the individual permit regulations found in 40 CFR 124 so the general
               permit will continue in force and effect until a new general permit is
               issued. Only those facilities authorized to discharge under the expiring
               GP that submit an NOI at least 90 days prior to the expiration of the GP
               are covered by the continued permit.

          5.    EPA is proposing that all facilities covered by the 2000 GP retain
               authorization under this GP if all NOI procedures are followed.


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          6.   This GP, like the 2000 GP, proposes coverage for operations that use
              hydraulicking to remove overburden or to mine. Such coverage would
              be subject to the no discharge requirements of the GP.

     B.   Limitations on Coverage

          1.   Many streams and stream reaches in Alaska have been designated as
              part of the federal wild and scenic rivers system or as a Conservation
              System Unit (CSU). Because this permit does not relieve a permittee
              of the requirements of other applicable federal, state or local laws,
              permittees should contact the district offices of the agencies that
              administer these systems for additional restrictions that may apply to
              operations on claims within these designated areas.

          2.   Many streams in Alaska have been designated by Alaska Department
              of Natural Resources, Office of Habitat and Permitting (OHMP) as
              needing a permit with additional restrictions. Because this GP does not
              relieve a permittee of the  requirements of other applicable federal, state
              or local laws, permittees should  contact OHMP. See Section IV.B.4. of
              this  Fact Sheet for more information.

     C.   Prohibitions

          1.   This GP does not apply to facilities that are proposed  to be located in
              National Parks System Units (i.e., Parks and Preserves), National
              Monuments, National Sanctuaries, National Wildlife Refuges, National
              Conservation Areas, Wilderness Areas, or National Critical Habitat
              Areas.

              This constitutes a change to the 2000 GP which also included "waters
              adjacent to the boundaries of areas designated as wild under the Wild
              & Scenic Rivers Act" in this section.  EPA, Region 10, has issued
              several individual permits with the same requirements as the GP to
              facilities in this designated area.  EPA has never received a comment
              on a draft permit that indicated special requirements were necessary
              for operating in these areas.  So EPA is proposing to remove this
              prohibition from the GP. If compelling comments are  received contrary
              to this action, EPA will consider them in finalizing this GP.

          2.   This permit does not apply to wetlands designated in the 1995
              Anchorage Wetlands Management Plan.

          3.   Hydraulicking facilities that have a discharge are not covered by the
              draft GP and would need  to apply for an individual permit.
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          4.    Discharges from the following beneficiation processes are not
               authorized under this permit: mercury amalgamation, cyanidation, froth
               floatation, heap and vat leaching.

     D.   Individual Permits

          1.    Owners or operators covered by a general permit may be excepted
               from coverage by applying to the Director of the NPDES program for an
               individual permit. This request must be made by submitting an NPDES
               permit application, together with  supporting documentation within 90
               days of publication by EPA of a final general  permit in the Federal
               Register, or 180 days prior to the commencement of operation of a new
               source or new discharger.

          2.    The Director may require any person authorized by a general permit to
               apply for and obtain an individual permit, or any interested person may
               petition the Director to take this action.  The Director may consider the
               issuance of an individual permit when:

               a.   The single discharge or the cumulative  number of discharges
                   is/are a significant contributor of pollution;

               b.   The discharger is not in compliance with the terms and conditions
                   of the general permit;

               c.   A change has occurred in the availability of demonstrated
                   technology or practices for  the control or abatement of pollutants
                   applicable to the point source;

               d.   Effluent limitation guidelines are subsequently promulgated for the
                   point sources covered by the general permit;

               e.   A Water Quality Management plan containing requirements
                   applicable to such point sources is approved; or

               f.   Circumstances have changed since the time of the request to be
                   covered so that the discharger is no longer appropriately
                   controlled under the general permit, or either a temporary or
                   permanent reduction  or elimination of the authorized discharge is
                   necessary.

     E.   New Source Notification Requirements

          EPA has decided that the changes to  the Mechanical GP are not significant
          enough to warrant a new Environmental Assessment (EA) under the
          National Environmental Policy Act (NEPA). At this time EPA is issuing a
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          Finding of No Significant Impact (FNSI) based on the EA issued in
          December 1993.

          An NOI must be submitted by January 1 of the year of discharge from a new
          facility or a facility established since 1988 subject to New Source
          Performance Standards (NSPS) that has not previously been covered by a
          permit. Each new source will have an EA prepared to make a determination
          of impacts in compliance with NEPA.

II.   REGULATORY HISTORY OF PLACER MINING IN ALASKA

     Regulation of discharges from gold placer mining operations in Alaska has been a
     matter of controversy since enactment of the Clean Water Act. Starting in 1976
     and 1977, EPA issued approximately 170 individual NPDES permits to Alaskan
     gold placer miners. Those permits were challenged administratively. Some
     parties argued that the permits were not stringent enough, others argued that the
     permits were too stringent. EPA issued an additional 269 individual  NPDES
     permits for gold  placer mining in 1983. All of those permits were challenged
     judicially in Trustees for Alaska v. EPA. 749 F.2d 549 (9th Cir. 1984).

     EPA issued a new round of individual permits (446 in total) in 1984 to replace
     expiring permits and to incorporate new promulgated regulations. In 1985, EPA
     modified the 1984 permits, based on the Trustee for Alaska decision, and issued
     93 additional permits. In 1987, EPA issued an additional 368 new permits. The
     1987 permits were the subject of litigation based  on allegations that  EPA and the
     State unreasonably delayed acting on requests for hearings on those permits in
     Stein v. Kelso. Case No. F89-21 Civil (D.Alaska)  (litigation against EPA). The
     case against EPA was eventually dismissed as moot on April 12, 1990.

     The permits EPA issued in 1985 and 1987 were challenged administratively and
     ultimately, judicially in Ackels v.  EPA. 7 F.3d 862 (9th Cir. 1993). A decision by
     the State of Alaska to certify the 1985 permits was ultimately resolved by the
     Alaska Supreme Court in Miners Advocacy Council, Inc. v. State Dep't of Envtl.
     Conservation. 778 P.2d 1126 (Alaska 1989), cert, denied. 493 U.S. 1077 (1990).
     The State's certification of the 1987 permits was also challenged in Stein v. Kelso.
     846P.2d 123 (Alaska 1993).

     EPA also was sued in the United States District Court for the District of Alaska in
     1986. That case raised a variety of statutory and constitutional issues, that were
     ultimately dismissed or resolved in the federal courts.  One of the concerns raised
     in the 1986  litigation, whether EPA had a duty to  promulgate national effluent
     limitations guidelines for the gold placer mining point source category, was
     eventually resolved when EPA published  such guidelines in 1988. (See 40 CFR
     Part 440 Subpart M). Those guidelines were the subject of litigation in Rybachek
     v. EPA. 904 F.2d 1276 (9th Cir.  1990).
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     On June 30, 1992, EPA received a notice of citizen suit, alleging that EPA failed to
     perform a non-discretionary duty to regulate suction dredge gold placer mining
     operations in Alaska. At that time, EPA decided it would issue individual permits
     for mechanical placer mining operations (for the 1993 mining season) and
     propose a general permit for suction dredge operations. On January 14, 1994,
     EPA proposed a general permit that extended coverage to mechanical as well as
     suction dredge operations [59 FR 2504 (Jan. 14, 1994)]. After responding to
     public comment, EPA issued the final general permit on May 13, 1994 [59 FR
     28079 (May 31, 1994)]. On September 28, 1994, two environmental groups filed
     a petition for review of the general permit in the Ninth Circuit Court of Appeals.

     On November 18, 1996, EPA and the two environmental groups entered into a
     settlement agreement to resolve the challenge to the general permit. Pursuant to
     the agreement, EPA agreed to issue three separate general permits to modify and
     supersede the original general permit challenged by the environmental groups in
     1994.  The settlement agreement also required EPA to complete two studies
     related to the impact of placer mining on the natural environment in Alaska. One
     study was to address the discharge of metals by placer mining operations and the
     other was to address the impact of suction dredge mining.

     EPA issued three modified general permits on December 6, 1996,  one for
     mechanical operations, one for medium-size suction  dredge operations, and one
     for small suction dredges [61 FR 64796, December 6, 1996].  On April 4, 1997,
     three environmental groups challenged these permits.  No. 97-70365 (9th Cir). In
     a separate action, the Alaska Miners Association (AMA) also challenged the
     general permits. No. 97-70379 (9th Cir.).  These cases were consolidated on May
     5, 1997. The challenge by the AMA was dismissed on January 21,1999.

     During the summers of 1997 and 1998 EPA staff and EPA contractors collected
     data at 31 placer mine sites and several suction dredge sites. These data were
     analyzed and presented in two final reports, one entitled "Alaska Placer Mining
     Metals Study" and the other entitled "Impact of suction dredging  on water quality,
     benthic habitat, and biota in the Fortymile River, Resurrection Creek, and
     Chatanika  River, Alaska." The environmental groups believed that the suction
     dredge report did not address all of the required elements as set out in the 1996
     settlement agreement.

     To avoid further litigation over the general permits, EPA and the environmental
     groups entered into another settlement agreement. Pursuant to the agreement,
     EPA agreed that further study was necessary to quantify the full impact of suction
     dredge mining on the natural environment and that further research should  be
     conducted before conclusions are reached about the impact of suction dredge
     mining on Alaska streams. EPA further agreed that by January 7,  2000, it would
     transmit to the Federal Register any necessary revisions to  the modified general
     permits to address the results of the metals study. As a result, the environmental
     groups' petition to review the three general permits was dismissed on August 31,
     1999.

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     EPA transmitted the 2000 draft general permit to the Federal Register on January
     7, 2000. The draft GP was published in the FR on January 14, 2000.  The final
     GP was published on August 31, 2000. The permit was effective on October 3,
     2000.

     As of February 2005,  340 operations have active coverage under the GP.  Re-
     notice,  according to the 2000 GP, should occur by July 5, 2005 (90 day prior to the
     expiration date).

III.   INDUSTRY DESCRIPTION

     Placer mining involves the mining and extraction of gold or other heavy metals
     and minerals primarily from alluvial deposits.  These deposits maybe in existing
     stream beds or ancient, often buried, stream deposits, i.e. paleo or fossil placers.
     Many Alaskan placer deposits consist of unconsolidated clay, sand, gravel, cobble
     and boulders that contain very small amounts of native gold or other precious
     metals.  Most are stream deposits that occur along present stream valleys or on
     benches or terraces above existing streams.  Beach placer deposits have been
     and continue to be important producers in Alaska. These deposits, most notable
     near Nome, include both  submerged and elevated beach placer  deposits.

     Essential components of placer mining include overburden removal, mining of the
     gold placer gravels, and processing (gold recovery).

          1.    Overburden Removal

               Various types  of overburden include barren alluvial gravels, broken
               slide rock, or glacial deposits. In some parts of Alaska the pay gravels
               are overlaid by silty, organic-rich deposits of barren, frozen  material
               generally comprised of wind-blown particles (loess). Particularly high
               ice content is common. Most facilities utilize mechanical methods for
               removal of overburden because  they generally use the same
               excavating equipment for mining.

               Overburden can also be removed by hydraulicking. Hydraulicking
               consists of the loosening of material  by water delivered under pressure
               through a hydraulic giant (monitor).

          2.    Mining Methods

               Placer mining  methods include both dredging systems and  open-cut
               mining.

               Dredging systems are classified  as hydraulic or mechanical (including
               bucket dredging), depending on  the methods of digging. Suction
               dredges, the most common hydraulic dredging system, are quite

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               popular in Alaska with the small or recreational gold placer miner.  Like
               all floating dredges, suction dredges consist of a supporting hull with a
               mining control system, excavating and lifting mechanism, gold recovery
               circuits, and waste disposal system. All floating dredges are designed
               to work as a unit to dig, classify, beneficiate ores and dispose of waste.
               Because suction dredges work the stream bed rather than  stream
               banks, the discharge from suction dredges consists totally  of stream
               water and bed material.

               Open-cut methods commonly used in Alaska involve the use of
               bulldozers to remove overburden, push pay dirt to sluiceboxes, stack
               tailing and construct ditches ponds and roads.  At some sites, loaders
               are used to move material.

          3.    Processing Methods

               A large percentage of the present gold  placer mining operations use
               some type of sluice box to perform the  primary processing  function,
               beneficiation.  An increasing number of jig plants are also being used at
               open-cut mines. Many operations make use of feed size classification
               that involves the physical separation of large rocks and boulders from
               smaller materials such as gravel and sand. The object of classification
               is to prevent the processing of large-sized material that is unlikely to
               contain gold values.  Commonly used classification equipment
               includes: grizzlies, trommels and static or vibrating screens. The most
               common gold recovery method is sluicing. A sluice is a long, sloped
               trough into which water is directed to separate gold from ore. A slurry
               of water and ore flows down the sluice and the gold, due to its relatively
               high density, is trapped in riffles along the sluice.

IV.   RECEIVING WATER

     The receiving waters are the waters of United States and the State of Alaska  most
     of which are classified in the Alaska Water Quality Standards [18 AAC 70]
     (AWQS) as Classes (1)(A), (B),  (C), and (D) for use in drinking, culinary and food
     processing, agriculture, aquaculture, and industrial water supply; contact and
     secondary recreation;  and growth and propagation of fish,  shellfish, other aquatic
     life, and wildlife.

     Some of the receiving  waters have  been reclassified  as industrial use only. These
     are Isabell Creek (upper), Lillian Creek,  Lucille Creek, Olive Creek (upper), and
     Ruth Creek near Livengood and Nolan Creek and all its tributaries excluding
     Acme Creek near Wiseman.

     This permit will be available for dischargers in reclassified waters. The AWQS
     contained in this permit are more stringent than would be applied in an individual
     permit in these locations. A facility located on any of the above receiving water

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     may apply to ADEC for a turbidity and/or arsenic modification or for an individual
     NPDES permit under Section I.D.1.

V.   EFFLUENT LIMITATIONS

     In establishing permit limits, EPA first determines which technology-based limits
     must be incorporated into the permit. EPA then evaluates the effluent quality
     expected to result from these controls to see if it could result in any exceedences
     of the water quality standards in the receiving water.  If exceedences could occur,
     EPA must include water quality-based limits in the permit. The draft permit limits
     will  reflect whichever requirements (technology-based or water quality-based) are
     more stringent.

     A.    No Discharge Facilities:

          Increasingly, EPA has received NOIs for permit coverage that indicate the
          facilities are no discharge facilities except in the case of a precipitation
          related event. In  1998, a review of NOIs showed that 42% stated zero
          effluent flow while an additional 18% reported flows of less than  50 gallons
          per minute (gpm). EPA received 340 NOIs during the 5 year cycle of this
          GP.  Of these 340, 168 or 49% indicated there would be no discharge.  An
          additional 4 NOIs indicated flows of less than 20 gpm.

          Because a storm exemption gives the permittee relief from the technology-
          based requirements  of the regulations and the receiving water is expected to
          be similarly affected  by the precipitation event, EPA has determined that
          numeric effluent limitations are not necessary. Instead, a "no discharge"
          provision with a storm exemption is included in the draft GP and Best
          Management Practices (BMPs) have been developed.

          These BMPs are supplemented by required effluent monitoring in the event
          of a discharge. The  frequency of effluent  monitoring will indicate whether the
          design size requirement should be reevaluated in future permitting actions.

          If a discharge occurs during dry weather, EPA would require the facility to
          follow the requirements of the permit for Discharging Facilities.

     B.    Discharging Facilities

          For the purpose of this permit, discharged wastewater consists of incidental
          waters commingled with process waters used to move the ore to and through
          the beneficiation  process, water used to aid in classification, and water used
          in gravity separation.

          1.    Technology-Based Limitations

               Pursuant to 40 CFR 440.143, BAT and NSPS requirements are as

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               follows:

               a.    The concentration of settleable solids in wastewater discharged
                    from an open-cut mine plant or a dredge plant site must not
                    exceed an instantaneous maximum of 0.2 ml/L.

               b.    The volume of wastewater that may be discharged from an
                    open-cut mine plant or dredge plant site must not exceed the
                    volume of infiltration, drainage and mine drainage waters that is in
                    excess of the make-up water required for operation of the
                    beneficiation process.

                    The effect of this requirement is to prohibit the discharge of any
                    wastewater during periods when new water is allowed to enter the
                    plant site.

               These technology-based requirements are specified in Permit Part II.B.

          2.    Water Quality-Based  Limits

               EPA has concluded, based on review of the WQS  and available
               sampling data, that turbidity and arsenic must be limited in order to
               meet the State WQS.

               a.    Turbidity:

                    According to the WQS, the most restrictive turbidity criteria
                    applies to fresh water sources classified for water contact
                    recreation uses. This criterion [18 AAC 70.020(b)(1)(B)(i)] state
                    that turbidity . . . "Shall not exceed 5 NTU above natural
                    conditions when the natural turbidity is 50 NTU or less; and more
                    than 10% increase in turbidity when the natural condition is more
                    than 50 NTU, not to exceed a maximum increase of 15 NTU."
                    The criterion for Water Supply, Drinking, Culinary and Food
                    Processing [18 AAC 70.020(1 )(A)(i)] is identical except that the
                    maximum increase is 25 NTUs.

                    The draft GP contains  a turbidity limit that would assure
                    compliance with water quality standards under worst case
                    conditions. That is, the turbidity in the effluent must not be more
                    than 5 NTUs above the background turbidity  level in the receiving
                    stream. This condition accounts for naturally occurring turbidity in
                    the receiving water and allows the effluent to contain an additional
                    5 NTUs of turbidity where the receiving water is naturally turbid.
                    The permit condition does not account for those situations where
                    naturally occurring turbidity would allow an increase of up to 15
                    NTUs, nor does it account for the dilution effects of the receiving

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                   stream. The reason for assuming worst case conditions is that
                   EPA does not have current site-specific information to establish
                   end-of-pipe limitations for each of the permits being processed.

                   Although worst case conditions are assumed in the draft permit,
                   EPA will consider modifying the turbidity limitation to account for
                   the dilution effects of the receiving stream. EPA will include
                   turbidity modifications  on receipt of an individual 401  Certification
                   of a mixing zone from ADEC.
               b.   Arsenic

                   The arsenic effluent limitation is based on the "Withdrawal from
                   Federal Regulations of the Applicability to Alaska's Waters of
                   Human Health Criteria" which was published in the Federal
                   Register on March 2, 1998 [63 FR 10140] and became effective
                   on April 1, 1998. This rulemaking withdrew the human health
                   criteria for arsenic for Alaska and  made the drinking water
                   maximum contaminant level (MCL) of 50 ug/L the applicable
                   standard protective of the designated uses of the receiving waters
                   covered by the GP.

                   The effluent limitation proposed for arsenic is a daily maximum
                   limit of 50 ug/L This is based on  the Primary Drinking Water
                   MCL applicable through 18 AAC 70.020(1 )(A) for Toxic and other
                   Deleterious Organic and  Inorganic Substances.  EPA defines the
                   MCL as the "maximum permissible level of a contaminant" (40
                   CFR 142.2) so it is included as an instantaneous maximum limit.

                   The EPA MCL for arsenic is now 10 ug/L (66 FR 6975 as clarified
                   in 68 FR 14501). The state of Alaska Drinking Water Program is
                   planning to adopt this new standard  during 2005. If the standard
                   has been incorporated into the WQS before the permit is
                   finalized, the arsenic limit in  the GP will be 10 ug/L based on the
                   drinking water use in 18 AAC 70.020 including primary drinking
                   water MCL.

VI.   Monitoring Requirements

     Section 308 of the Clean Water Act and the federal regulations at 40 CFR
     § 122.44(i) require that permits include monitoring to determine compliance with
     permit requirements. Monitoring may also be required to gather data for future
     effluent limitations or to monitor effluent impacts on receiving water quality.  The
     permittee is responsible for conducting the monitoring and for reporting results to
     EPA.
AKG-37-0000                                                         Pag,15 of 27

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     A.   No Discharge Facilities

          The draft permit requires one turbidity sample of the discharge and upstream
          of the discharge point during a discharge event.  One sample of the
          discharge for arsenic is also required. The required daily facility inspection
          to ensure compliance with the BMPs in Permit Part II.D. assures that the
          facility will discharge only in those instances when precipitation is excessive.

     B.   Discharging Facilities

          The draft GP requires an annual arsenic sample in addition to daily
          settleable solids sampling.

          The data collected between 1997 and 1998 for EPA's Metals Study were
          reviewed for the preparation of a recommendation paper entitled "Permit
          Recommendations Resulting  from EPA's Metals Study." In this paper, EPA
          recognized that turbidity can be used as a surrogate for metals levels  in the
          effluent of placer mines.  To use turbidity as an effective surrogate, the
          proposed monitoring frequency is being increased to three times per week.
          The results of the Metals Study as well as the recommendations paper are
          discussed further in Appendix C.

          The reporting  requirement is based on 40 CFR § 122.48 which is specified in
          the permit as a submission of an Annual Report  (AR) by January 31st of each
          year for the previous year's activities.

VII.  BEST MANAGEMENT PRACTICES (BMPs)

     BMPs are measures that are intended to prevent or minimize the generation and
     the potential for the release of pollutants from industrial facilities to the waters of
     the United States through normal operations and ancillary activities.

     Pursuant to Section 301 (b)(2)  of the Clean Water Act, effluent guidelines were
     developed for the Category Ore Mining and Dressing Industry, Subcategory of
     Placer Mining that includes BMPs.  BMPs, in addition to numerical effluent
     limitations, are required to control or abate the discharge of pollutants in
     accordance with 40 CFR § 122.44(k). Most of the  BMPs in the draft permit are
     part of the Placer Mining Effluent Limitation Guidelines found at 40  CFR 440
     Subpart M.

     The draft permit requires compliance with the following BMPs:

     A.   The flow of surface waters (i.e., creek, river, or stream) into the plant site
          shall be  interrupted and these waters diverted around and  away to prevent
          incursion into the plant site.

               The intent of this BMP is to avoid contamination of nonprocess water,

AKG-37-0000                                                         Pag,16 of 27

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              reduce the volume of water requiring treatment and maximize the
              retention time and the capacity of the settling ponds. The diversion
              must totally circumvent any gold recovery units, treatment facilities, etc.

     B.   Berms, including any pond walls, dikes, low dams, and similar water
          retention structures shall be constructed in a manner such that they are
          reasonably expected to reject the passage of water.

              This BMP ensures that water retention devices are constructed
              appropriately. This may be achieved by utilizing on-site material in a
              manner that the fine sealing material (such as clays) are mixed in the
              berms with coarser materials. Berms should be toed into the
              underlying earth, constructed in layers or lifts and each layer thoroughly
              compacted to ensure mechanical and watertight integrity.  Other
              impermeable material such as plastic sheets or membranes may be
              used inside the berms when sealing fines are unavailable or in short
              supply. The side slope of berms should not be greater than the natural
              angle of repose of the materials  used in the berms or a slope of 2:1,
              whichever is flatter.

     C.   Measures shall be taken to assure that pollutant materials removed from the
          process water and wastewater streams will be retained in storage areas and
          not discharged or released to the waters of the United States.

              The intent of this BMP is to ensure that the investment in pollution
              control pays the maximum benefit in terms of reduced pollutant
              volumes reaching water of the United States.  These measures may
              include location of the storage ponds and storage areas to assure that
              they will not be washed out by reasonably predictable flooding or by
              the return of a relocated stream to its original stream bed.  Materials
              removed from settling ponds should be placed in bermed areas where
              liquids from the materials cannot flow overland to waters of the United
              States. It may be necessary, in some cases, to collect such liquids and
              pump or divert them back to the  settling pond for treatment.  This
              requirement applies both during  the active mining season and at all
              other times until reclamation is completed.

     D.   The amount of new water allowed  to enter the plant site for use in material
          processing shall be limited to the minimum amount required as makeup
          water.

              This requirement provides some of the same benefits as diverting water
              discussed in paragraph A, above. It reduces the volume of water
              requiring treatment, maximizes the capacity of the settling ponds, and
              assures that the amount of wastewater that is discharged is kept to a
              minimum.
AKG-37-0000                                                         Pag,17 of 27

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     E.   All water control devices such as diversion structures and berms and all
          solids retention structures such as berms, dikes, pond structures, and dams
          shall be reasonably maintained to continue their effectiveness and to protect
          from failure.

               The provisions of this BMP will ensure that water control devices are
               adequately maintained. This specifies that structures should be
               inspected on a regular basis for any signs of structural weakness or
               incipient failure.  Whenever such weakness or incipient failure becomes
               evident, repair or augmentation of the structure to reasonably ensure
               against catastrophic failure must be made immediately.

     F.   The operator shall take whatever reasonable steps are appropriate to assure
          that, after the mining season, all unreclaimed mine areas, including ponds,
          are in a condition that will  not cause degradation to the receiving waters over
          those resulting from natural causes.

               The purpose of this requirement is to assure that all reasonable
               measures are taken  to decrease the amount of pollutants being
               discharged to waters of the United States.

     G.   During each mining season, a permittee may not discharge into the receiving
          water within three hundred feet of any other upstream or downstream placer
          mining operation which is  discharging or from which it is apparent that a
          discharge has occurred.  Nor may a permittee discharge at a point within
          three hundred feet of the downstream edge of a mixing zone granted for any
          other upstream placer mining operation.

               This requirement will ensure that there are areas ofunimpacted
               substrate that exists between operations so that habitat is
               available for fish and the invertebrates upon which they prey.

     H.   Care shall be taken by the operator during refueling operations to prevent
          spillage into surface waters or to groundwater. Any spills shall be cleaned
          up using materials such as sorbent pads and booms.  All spills shall be
          reported to DEC by calling 1-800-478-9300.

               This requirement is included based on ADEC's draft §401 Certification
               which states:  Under 18 AAC  75.300: a person must notify the [ADEC]
               by telephone immediately in the result of a release or discharge of a
               hazardous substance.
AKG-37-0000                                                          Pag,18 of 27

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VIM.  OTHER PERMIT CONDITIONS

     A.   Oil Spill Requirements

          Section 311 of the Act prohibits the discharge of oil and hazardous materials
          in harmful quantities. The operator shall maintain fuel handling and storage
          facilities in a manner that will prevent the discharge of fuel oil into the
          receiving waters.  A Spill Prevention Control and  Countermeasure Plan
          (SPCC Plan) must be prepared and updated as necessary in accordance
          with the provisions of 40 CFR Part 112 for facilities with a storage capacity of
          660 gallons in a single container above ground, 1320 gallons in the
          aggregate above ground, or 42,000 gallons below ground.

          The Permittee must indicate in the AR if an SPCC Plan is necessary and in
          place at the site and  if changes were made to the Plan over the previous
          year.

     B.   Endangered Species Act (ESA)

          ESA requires federal agencies to consult with the National Marine Fisheries
          Service (NMFS) and the U.S.  Fish and Wildlife Service (USFWS) if their
          actions could beneficially or adversely affect any  threatened  or endangered
          (T&E) species. EPA sent a letter to the U.S. Fish and Wildlife Service and to
          the National Marine Fisheries  Service on January 3, 2005, requesting a
          species list for the coverage area of the general permit.

          In a letter dated February 23,  2005, NMFS stated that there are no marine
          mammals under their jurisdiction that will be affected by mining operations in
          freshwater streams.  Since this GP is not applicable to marine waters, EPA
          has determined that no adverse effect to NMFS ESA species will result from
          the issuance of this permit.

          In a letter dated February 23,  2005, USFWS listed several T&E species for
          Alaska along with one proposed (P) and one candidate (C) species. Their
          table included the short-tailed albatross (E, Gulf of Alaska, Aleutians, Bering
          Sea coast),  Aleutian  Shield Fern (E, Adak Island), Spectacled eider (T, W&N
          coastal Alaska), Steller's eider (T, southwestern, western and northern),
          Norther Sea Otter - SW Alaska population (P, Aleutian Islands, AK
          peninsula, Kodiak Island), and Kittlitz's Murrelet (C, coastal waters southern
          & northwestern Alaska).  USFWS concluded that this project is not likely to
          adversely impact list species so no further consultation is necessary.

     C.   Essential Fish Habitat (EFH)

          The 1996 amendments to the Magnuson-Stevens Fishery Management and
          Conservation Act set forth a number of new mandates for NMFS, regional
          fishery management councils and other federal agencies to identify and

AKG-37-0000                                                        Pag,19 of 27

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          protect important marine and anadromous fish habitat.  The action agency
          (in this case, EPA) must determine whether its actions may adversely impact
          EFH.

          The most likely harm to come to fish as a result of placer mining is sediment
          loading or decreased light penetration cause by elevated instream turbidity.
          Since a facility in compliance with this draft GP is not expected to cause
          significantly elevated sediment loads or instream turbidity, EPA has
          determined that no adverse effect to EFH will result from the issuance of this
          permit.

     D.   Consistency Determination

          This GP was previously found consistent on June 23, 2000. On January 13,
          2005, EPA requested information on the Alaska Coastal Management
          Program (ACMP) review.  On March 2, 2005, the Department of Natural
          Resources/Office of Project Management and Permitting (OPMP) sent a
          response letter. In its response, OPMP stated that with the minor proposed
          changes to the GP, a new ACMP review is not required.

     E.   State Certification

          Section 401 of the Clean Water Act requires EPA to seek certification from
          the State that the permit is adequate to meet State water quality standards
          before issuing a final permit. The regulations allow for the State to stipulate
          more stringent conditions in the permit, if the certification cites the Clean
          Water Act or State law references upon which that condition is based. In
          addition, the regulations require a certification to include statements of the
          extent to which each condition of the permit can be made less stringent
          without violating the requirements of State law.

          The Alaska Department of Environmental Conservation has provided a draft
          certification which has been included in this Fact Sheet as Appendix A.  If
          the state authorizes different or additional conditions as part of the final
          certification, the permit may be changed to reflect these conditions.

     F.   Permit Expiration

          This permit will expire five years from the effective date of the  permit.
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                  APPEND IX A - DRAFT §401 CERT IF I CAT I ON
                                                      FRANKH. MVRKOWSKI, GOVERNOR
                                                          410 Willoughby Avenue, Suite 303
                                                              Juneau, AK 99801-1795
                                                              PHONE: (907)465-5175
                                                              FAX:   (907)465-5177
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
DIVISION OF WATER
WASTEWATER DISCHARGE PROGRAM

                                  February 16, 2005

MikeLidgard                                                  ADEC Files: 900.60.001
NPDES Unit Manager                                                       900.68.002
USEPA
1200 Sixth Avenue
Seattle WA, 98101

RE: Draft 401 Certification of NPDES General Permits AKG-37-0000 and AKG-37-1000

Dear Mr. Lidgard;

On January 12, 2005 EPA Region 10 requested draft 401 certifications for the renewal of
NPDES General Permits AKG-37-0000 and AKG-37-1000, regulating discharges from placer
mining activities in Alaska.

The ADEC has enclosed the Draft Certificates of Reasonable Assurance to include as drafts in
the public notice process. These draft 401 certifications were created using the current NPDES
General Permits as preliminary draft permits. I look forward to working with your staff on the
renewal of these General Permits.

If you have any questions regarding these draft certifications please contact me at 907-451-2142
or at luke_boles@dec.state.ak.us.

Sincerely,

SIGNATURE ON FILE

Luke Boles
Environmental Engineering Associate
Wastewater Discharge Program

Enclosures:      Draft Certificates of Reasonable Assurance for NPDES  General Permits
                AKG-37-0000 and AKG-37-1000.

CC:
Cindi Godsey, EPA, Anchorage              Jack Kerin, ADNR/DMLW, Fairbanks
Shannon Stambaugh, ADEC, Anchorage      Mac McLean, ADNR/OHMP, Fairbanks
Steve McGroarty, ADNR/DMLW, Fairbanks  Bill Jefferss, ADNR/OPMP, Anchorage

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                                 STATE OF ALASKA
               DEPARTMENT OF ENVIRONMENTAL CONSERVATION
               DRAFT CERTIFICATE OF REASONABLE ASSURANCE
A Certificate of Reasonable Assurance, as required by Section 401 of the Clean Water Act, has
been requested by EPA, Region 10, forNPDES Permit No. AKG-37-0000, MECHANICAL
PLACER MINING IN ALASKA

Public Notice of the application for this certification will be made in accordance with 18 AAC
15.140.

Water Quality Certification is required for the proposed activity because the activity will be
authorized by an EPA permit identified as No. AKG-37-0000 and a discharge may result from
the proposed activity.

Having reviewed the preliminary draft permit, the Alaska Department of Environmental
Conservation certifies that there is reasonable assurance that the proposed activity, as well as any
discharge that may result, is in compliance with the requirements of Section 401 of the Clean
Water Act, which includes the Alaska Water Quality Standards (18 AAC 70), provided that the
following stipulations are adhered to:

1.    The ADEC authorizes the language contained in section II.B.4 allowing permittees to apply
for a turbidity mixing zone.

Rationale: In accordance with State Regulations 18 AAC 70.240, the Department has authority
to designate mixing zones in permits or certifications.  Any authorized mixing zones will ensure
that the water quality standards are met at all points outside of the mixing zone.

2.    Add the following language to section II.D as BMP #8:

Care shall be taken by the operator during equipment refueling to prevent spillage into
surface waters or to groundwater. Any spills shall be cleaned up using materials such as
sorbent pads and booms. All spills shall be reported to DEC by calling 1-800-478-9300.

Rationale: Under 18 AAC 75.300: a person must notify the [ADEC] by telephone immediately
in the result of a release or discharge of a hazardous substance.
February 23, 2005	                DRAFT
Date                                      Gretchen Keiser
                                          Program Manager
                                          Wastewater Discharge Program
AKG-37-0000                                                             Pag, 22 of 27

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                                 STATE OF ALASKA
               DEPARTMENT OF ENVIRONMENTAL CONSERVATION
               DRAFT CERTIFICATE OF REASONABLE ASSURANCE
A Certificate of Reasonable Assurance, as required by Section 401 of the Clean Water Act, has
been requested by EPA for NPDES Permit No. AKG-37-1000, ALASKA MEDIUM-SIZE
SUCTION DREDGE PLACER MINERS

Public Notice of the application for this certification will be made in accordance with 18 AAC
15.140.

Water Quality Certification is required for the proposed activity because the activity will be
authorized by an EPA permit identified as No. AKG-37-1000 and a discharge may result from
the proposed activity.

Having reviewed the preliminary draft permit, the Alaska Department of Environmental
Conservation certifies that there is reasonable assurance that the proposed activity, as well as any
discharge that may result, is in compliance with the requirements of Section 401 of the Clean
Water Act, which includes the Alaska Water Quality Standards (18 AAC 70), provided that the
following stipulations are adhered to:

1.    The ADEC authorizes  the 500 feet mixing zone for turbidity contained in section II. A and
the monitoring requirements contained in section n.B.l  of the draft permit.

Rationale: In accordance with State Regulations 18 AAC 70.240, the Department has authority
to designate mixing zones in permits or certifications. This mixing zone will ensure that the
water quality standards are met at all points outside of the mixing zone.

The Department considered all aspects required in 18 AAC 70.015 (Antidegradation) and 18
AAC 70.240-270 (Mixing Zones)  including, but not limited to, the potential risk to human health
and ecological resources of receiving waters and mixing zone modeling of the predicted effluent
quality from the discharge.

The Department finds that the size of the mixing zone authorized for discharge in this
certification is appropriate and provides reasonable assurance that existing uses of the receiving
waters outside of the mixing zone are maintained and fully protected.

2.    Amend section II.C.8 as noted in bold:

Care shall be taken by the operator during refueling of the dredge to prevent spillage into surface
waters or to groundwater.  Any spills shall be cleaned up using materials such as sorbent
pads and booms. All spills  shall be reported to DEC by calling 1-800-478-9300.

Rationale:  Under 18 AAC 75.300: a per son must notify the [ADEC] by telephone immediately
in the result of a release or discharge of a hazardous substance.
February 23, 2005	                DRAFT
Date                                      Gretchen Keiser
                                          Program Manager
                                          Wastewater Discharge Program

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             APPENDIX B -- BASIS FOR EFFLUENT LIMITATIONS

     A.   No Discharge Facilities:

          1.    Technology-based Limitations: Best Professional Judgement (BPJ)
               Determination

               EPA has determined that a no discharge requirement with a storm
               exemption and BMPs should serve as a basis for Best Available
               Technology/Best Conventional Technology (BAT/BCT) effluent
               limitations. This determination is based on the following
               considerations:

               a.   Age of equipment and facilities, processes involved.

                   Regardless of the age of the facilities, mechanical operations and
                   hydraulicking facilities operate similarly. Settling  ponds are
                   incorporated into the process to handle the amounts of water and
                   material used.

               b.   Engineering aspects of the application of various types of control
                   techniques; process changes

                   Many of the operations submitting NOIs in the past have indicated
                   that the only discharge that would occur is precipitation related.
                   EPA issued three individual "no discharge" permits  to
                   hydraulickers in 1999. The permittees at the time indicated that
                   there would be no discharges except in the event of extreme
                   precipitation. At this time, no other potential treatment methods
                   are being considered as a basis for BAT at these facilities.

               c.   Cost Considerations

                   Since Region 10's determination that the currently utilized
                   treatment technology will be  utilized as BAT/BCT treatment for
                   these facilities, there is no incremental cost involved in attaining
                   the technology-based limits of the draft permit.

     B.   Discharging facilities:

          1.    Technology-based effluent limitations

               The CWA requires industries to apply treatment technology
               representing BAT that is economically achievable. The BAT and the
               New Source Performance Standards (NSPS) [40 CFR 440 Subpart M]
               requirements specify the use of settling ponds plus total  recirculation of
               process wastewater as the selected treatment technology.  However,
               the regulation  does allow the discharge of incidental waters (including
               waters that enter a mine through precipitation, snow melt, drainage
               water, ground  water infiltration and the melting of permafrost) that have
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               commingled with process waters, provided that these incidental waters
               are in excess of the make-up water required, are treated in settling
               ponds and do not exceed 0.2 ml/L settleable solids prior to discharge.

          2.    Water Quality-based Limitations

               Section 301(b)(1)(c) of the Act requires the imposition of". . . any more
               stringent limitation, including those necessary to meet water quality
               standards, ... or required to implement any applicable water quality
               standard established pursuant to this Act" by July 1, 1977. All
               discharges to state waters must comply with state and local coastal
               management plans as well as with state water quality standards,
               including the state's antidegradation policy. Discharges to state waters
               must also comply with limitations imposed by the state as part of its
               coastal management program  consistency determination and of its
               certification of NPDES permits under section 401 of the Act.

               The NPDES regulations at 40 CFR 122.44(d)(1) require that permits
               include water quality-based limits that "Achieve water quality standards
               established under section 303  of the CWA, including State narrative
               criteria for water quality."

               EPA has concluded, based on review of the WQS and available
               sampling data, that turbidity and arsenic must be limited in order to
               meet the State WQS.

               a.    Turbidity: The most stringent turbidity standard, 5 NTUs above the
                    natural condition, is found in 18 AAC 70.020(b)(12)(A)(i) protects
                    for the drinking,  culinary and food supply use. The WQS allow for
                    a mixing zone approved by ADEC.

                    The basic form of this equation is:

                              0,0,  + Q2C2 = Q3C3,

                     where    C., = upstream turbidity;
                              C2 = effluent turbidity;
                              C3 = downstream turbidity after mixing where
                                   the allowable increase is 5 NTU above
                                   background (C, + 5 NTU);
                              Q., = stream flow downstream from any diversion
                                   and upstream from the discharge;
                              Q2 = effluent flow; and,
                              Q3 = total stream flow downstream from
                                   discharge after complete mixing.

               b.    Arsenic:  The most stringent arsenic standard is 50 ug/L found
                    Table I of the Alaska Water Quality Criteria Manual as referenced
                    in 18 AAC  70.020(b)(11)(A)(i) protects for the drinking, culinary
                    and food supply use.  Currently, the ADEC Drinking Water

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                    Program is in the process of adopting a new drinking water
                    standard. If this new standard (10 ug/L) is incorporated into the
                    WQS prior to the final issuance of this GP, the new standard
                    would become the permit effluent limit.  Permittees may request a
                    modified arsenic limit reflecting the arsenic concentrations
                    naturally present in the receiving waters as determined by ADEC.
                    The provisions for this determination may be found in Permit Part
                    II.B.S.a.

     C.   Pursuant to Section 301 (b)(2)  of the Act and 40 CFR 122.44(k)(3), BMPs are
          being proposed in the permit.  These practices are reasonably necessary to
          carry out the Act's goals of eliminating the discharge of pollutants  as much
          as practicable and to maintain water quality.
AKG-37-0000                                                          Pag, 26 of 27

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                        APPENDIX C -- REFERENCES

EPA,  NPDES Permit Writer's Manual.  Office of Water, Office of Wastewater
     Management, Permits Division. Washington, DC. 20460; EPA-833-B-96-003,
     December 1996, 220pp.

EPA, Technical Support Document for Water Quality-based Toxics Control. Office of
     Water Enforcement and Permits, Office of Water Regulations and Standards.
     Washington, DC, 20460; EPA/505/2-90-001, March 1991, 145pp.

EPA, Alaska Placer Mining Metals Study. Office of Environmental Assessment, Region
     10, Seattle, Washington 98101; EPA910-R-98-003, April 1998.

EPA, Alaska Placer Mining Metals Study - Year Two. Office of Environmental
     Assessment, Region 10, Seattle, Washington 98101; EPA910-R-99-004, April
     1999.

EPA, "Permit Recommendations Resulting from the EPA Metals Study." Office of
     Water, Region 10, Anchorage, Alaska 99513; unpublished, December 1999.

Society of Mining Engineers, Mining Engineering Handbook. 1973.

Administrative Record for the 2000 Re-issuance of the NPDES GP for Mechanical
     Placer Mining in Alaska (AKG-37-0000).
AKG-37-0000                                                      Pag, 27 of 27

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