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<br />COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division
<br />Rationale -Page 32 Permit No. CO-0gd5675
<br />Vlll. CI(ANGES TO PERMIT AND RATIONALE FOLLOWING PUBLIC NOTICE
<br />First Public Notice Period, Comment Letters and Public Meet/ng: The Battle Mountain Resources, Inc.
<br />(BMRI) draft discharge permit and rationale went fo public notice on March 31, 2000. Tho /ollowin;~ comment
<br />letters were received during the public notice period. Based upon these comments, as well as other information
<br />That was evaluated, the Division made some changes to the BMRI rationale and permit, which are in part
<br />discussed in the paragraphs below.
<br />• Battle Mountain Resources Inc., dated May 1, 2000
<br />• Environmental Pro[ectton Agency, Region Vlll, dated May 1, 2000
<br />• Costilla County Conservancy DisMct (CCCD) and People's Attemative Energy Services (PAES) -from Lori Potter,
<br />Kelly, Haglund, Gamsey+Kahn, LLC, Attorneys at Law., dated May 8, 2000
<br />• Rocky Mountain Consultants, Inc. (RMC), Hydrokinetics, Inc. (HKI), and Hydrodynamics, Inc. (HDI), from Bruce
<br />Marshall, submitted to Lori Potter and attached to that comment letter, dated May 7, 2000
<br />• Shalom Ranch, two letters from Stephen Hams and Connie King, Merrill, Anderson, King 8 Harris, LLC, /Ittorneys
<br />at Law, dated April l8, 2000 and April 27, 2000
<br />• Costilla County Committee (or Environmental Soundness, from Rachol Conn, CES Project Manager, dated April
<br />27, 2000
<br />• Colorado Acequia Association, from Ernest Vigil, President, and Megan Corrigan, Culebra Basin Cumulative
<br />Watershed Ef/ects Assessment Project Coordinator, dated April 27, 2000
<br />• The Summitville TAG, from Wendy Mellott, Administrator/Coordinator, dated Apri128, 2000
<br />• Mineral Policy Center, from Dan Randolph, Southwest Circuif Rider, dated Mays, 2000
<br />• Costilla County Planning 8 Zoning, from Santos Trey Martinez, Costi/!a County Land Use Administrator, c'ated
<br />Apri128, 2000
<br />In addition to the above comment letters most of which also requested a public meeting, there were approximately
<br />30 to 351etters from individuals requesting a public meeting on this discharge permit. The public meeting wa:~
<br />held on June 27, 2000 in San Luis, Colorado.
<br />Issues Indicated in Public Comment Letters Submitted During the First Public Notice:
<br />The following topics were addressed in the comment letters:
<br />Issuing the permit to both operator (Battle Mountain Resources, Inc.) and owner (Battle Mountain Gold Company)
<br />Issues related to outtall 001:
<br />• The basis for determining the antidegradation review/antidegradation limitations (using Station RS-5 vs. RS-1 or RS-2)
<br />• Including limitations and monrtoring for aluminum ((or 001 and 002)
<br />• Concems related to radioactive consfrtuents in the discharge ((or 001 and 002)
<br />• Defining the initial and later time periods (or the discharge
<br />Issues related to outta11002:
<br />• Better definitions for the location and requirements for outtall 002
<br />• Utilizing monitoring wells to define outtall 002
<br />Addressing specific flow and other limitations and monitoring requirements for outtall 002
<br />• Identifying seepage contributions as part o(the mass balance water quality standard-based calculations
<br />• Not referencing the CDMG requirements (or TR-26 and TR-28 in associaton with the requirements for outtall 002 in
<br />the CDPS discharge permit
<br />• Concems related fo short-term West Pit groundwater discharge issues and long-term water groundwater discharge
<br />issues (defining a window (or identification of ground water (lowing through a restricted zone as a point of
<br />compliance; utilization of additional ground water monitoring wells; installation of a slurry wall)
<br />• Concems regarding the Best Management Practices requirements described for outtall 002
<br />• Including additional outtalls (or discharge points), limits, and monitoring (or the four surface seeps; ensuring that the
<br />seeps are contained and will not discharge to surface waters
<br />Other Groundwater Related Issues:
<br />• Concems with the mining operation and reclamation activities impacting the ground water hydrdogy in the viGnity
<br />• Impacts upon wells dawngredient o/the facility
<br />• Indications o/locations o(drtnking water sources in the vicinity (Shalom Ranch, San Luis alluvial wells, etc.)
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