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COLORADO DEPARTh1ENT OF HEALTH, Water Quality Control Division <br />Rationale -Page 18, Permit No. CO-0043648 <br />For cyanide, the standard for the receiving stream is bused upon 'free" cyanide concentrations. <br />However, there is no analytical procedure for measuring the concentration of free cyanide in a <br />complex e,Qluent. Therefore, ASTM (Anun•ican Society for Testing and Materials) analytical procedure <br />D2036-81, Method C, will be used to measure weak acid dirsociable cyanide in the effluent. This <br />analytical procedure will detect free cyanide plus those forms of complex cyanide that are mast readily <br />converted to free cyanide. <br />The calculated effluent limitation (stream standard) of 0.005 mg/! is less than the detection limit of <br />0.030 mg/1 for this method. Therefore, a limit for weak acid dissociable cyanide will be specked, and <br />will be set equal to the duect{on limit. Provided weak acid dlssociable cyanide concentrations are <br />less than the method detection limit of 0.030 mg/1, it will be assumed that the 0.005 mg/l fret cyanide <br />standard is being adequately protected. <br />For metals with dissolved standards, corresponding ejjluent limits are based upon the potentially <br />dsso[ved method of analysis, except for hezavalent chromium, which must 6e analyzed for using the <br />dissolved method. <br />In order to determine which metals require e, jfluent limiu, the receiving stream data presented in <br />section III. A. was compared to the corresponding calculated limits (which are equal to stream <br />standards). For metals with treasured concentrations exceeding or within a reasonable range of the <br />calculated limits, the limits were included in the permit. As noted in the preceding section of this <br />rationale, the water quality based metals limits were, in all cases, more stringent than the federal <br />effluent guidelines, and therefore will be the ones included in the permit. <br />e. Limitations Other Than Those Based Uonn Water pualirv Standards Federal Guidelines. and State <br />EAluent ReAUlations: <br />For discharge points OOIA, OOIB, 004A, OOSA 006A and 007A, no limits were specified for flow or <br />hnr-lness, but these parameters mast be monitored in order to provide information that might be used <br />in the determination of whether or not a discharge hat occurred, and ro more precisely evaluate what <br />the impact of any discharge might be to the receiving stream. <br />The limit.: and monitoring conditions specfied jot discharge points 002A and 003A are intended to <br />provrde assurance that the various leach pad liner systems are functioning properly. The seepage <br />related parameters and action codes listed in Table V!-2 are based upon project design documents that <br />were submitted as part of the application jot the Colorado Division of Minerals and Geology mining <br />permit. <br />4. Discussion of Effluent Limitations -Application to Specific Discharge Points <br />n. All Potential Pollutant Sources - "No Di::charpe" Limitation <br />Except as provided Uv the Annual Precipitation or Stormwater exemptions discussed below, this permit <br />is bnscd upon the premise that there will be no discharge of pollutants from any potential point <br />source, including those points specflcally identfled below. <br />b. Point 007A - Discharfes From the Valley Leach Facilirv That Ounlify For Annual Precipitation or <br />Srorrn Eretnntions. and Points OOIA. 001 B - Arenua Gulch at Station AGI. S <br />Any discharges from the valley leach facility that would qualify for the uemptiorts described in <br />sections Vl.A.1. and 2. (point 007AJ would likely be surface discharges. Due to the fact that any suck <br />discharges could entrain significan[ qunn[ities of suspended solids, the 7SS limit from federal <br />guidclirses will be applied. <br />