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Page 3' <br />COLORADO DEPARTMENT OF HEALTH, Wafer Quality Control Division <br />Rationale -Page 35 Pennlt No. CO-0045675 <br />concentrations of constituents which are related to West Pit and RRO Seco alluvial groundwater, along with extensive <br />monitoring and reporting, provitle multiple layers of environmental and public health protections. <br />Vlll. CHANGES TO PERMIT AND RATIONALE FOLLOWING PUBLIC NOTICE <br />First Public Notice Period, Comment Letters and First Public Meeting: (Cont.): <br />Comment: The permit should be issued to both operator (Battle Mountain Resources, Inc.) and owner (Battle Mountain <br />Gold Company) <br />Response: <br />A number of the comments asserted that both BatRe Mountain Gold as well as Battle Mountain Resources Inc. ('BMRI' be <br />identified as the permittee on the final permit. In strict acconiance with the Colorado Discharge Permit System <br />Regulations Rule 61.4!11. the original permit application (or the facility ident~ed BMRI as the applicant because BMRI <br />owned the land, BMRI employees operated the facility and BMRI is the permittee on virtually all other permits which have <br />been in place for the facility since its iniiial construction. However, as BMRI has indicated in discussions with the WOCD <br />throughout this process, Battle Mountain k commfNed to a satisfactory technical resolution o(the West Pit issues and will <br />respond to such comments by amending its application to reflect both entities as co-permittees for the facility. An <br />amended applicant identification information will be submitted. <br />Comments: Issues related to ouNall 001: <br />- The basis for determining the antidegradation review/antidegradation limitahions (using Station RS-5 vs. RS-1 <br />- Including limitations and monitoring (or aluminum (for 001 and 002) <br />- Concerns related to radioactive constituents in the wastewater sources and the discharges (001 and 002) <br />- Defining the initial and later lime periods for the discharge (for 001 and 002) <br />Response: <br />Antidegadation: Several letters contained comments regarding the anbdegradation review and the antidegradation-based <br />limitations. BMRI commented that antidegredabon should not apply for this permit. The Division has determined that the <br />anbdegradation-based limitations in this permit are still applicable, since the discharge will be occurring for a longer term <br />(more than one year), and this is not a temporary activity. Other comment letters stated that the baseline shoultl be <br />determined from data at Rico Seco Monitoring Station RS-1 and/or RS-2, rather than Station RS-5. The Division has <br />reevaluated the data and conditions associated with each o(these three surface water sampling stations, and determined <br />that the RS-1 location is not a representative area for a baseline assessment. (See further discussions related to this <br />comment in pages 5-6 of Appendix D, EPA comments, item 1.) The Division also determined the baseline loading (or both <br />of the downstream stations RS-2 and RS-5 and compared the anddegredation-based limits for each baseline loading (as is <br />summadzed in Appendix C (or the 250 gpm discharge flow, along with a comparison with the calculated water qualify <br />standard-based limitations). Based upon this evaluation, the Division has concluded that the baseline loading will still be <br />based upon Station RS-5, which overall results in more stringent and protective limitations in the permit. Further related <br />comments and responses to the antidegradation issues are included in Appendix D. <br />Aluminum: Based upon the concentrations of aluminum that have been defected in the pit bac~ll monitoring wastewater <br />source (as indicated in Appendix A), the Division finds that there is a reasonable potential (or aluminum to occur in the <br />untreated ground water source. Thus, limttadons and monitodng have been added for potentially dissolved aluminum (or <br />the 001 ouNalls. Since there should be no discharge from the West Pit to 002, there are no limits or routine monitorng (or <br />aluminum at this location. However, Nseeps should be identified within the historically defined area as shown in figure 2 of <br />the permit, parameters such as potentially dissolved aluminum, dissolved iron, and dissolved manganese must be <br />analyzed in samples collected. <br />Radioactive Consttuents: With respect to the radioactive constituents that are associated with Gross Alpha Activity, <br />discharge permits in Colorado have spec~cally identified that this is primarily associated wRh radium (226+228) and <br />uranium. Where radioactive constituents are limited for other mining discharge permis, limits and monitoring are specked <br />(or these two constituents, and these limits are based upon the statewide standards for all surface waters. The BMRI <br />discharge permit explicitly sets limits on the concentrations o/uranium and radium discharged from the water treatment <br />facility. <br />Time Pedods: In the orgginal public noticed draft permit, there was reference to an iniial time period that included a higher <br />discharge Row rate (400 gpm), with a later time pedod when discharge flows would be expelled to decrease. Thus, tiered <br />limitations in the permit were developed and these limits along with discharge flow rate limits are based upon discharge <br />Row values 01400, ?50, end f00 gallons per minute (gpm). With the revisions and updates made for this facility's permit, <br />there is no longer any defined periods /or initial and later discharge flows. Thus, previous comments related to flows are <br />