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Page 3 <br />COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br />Rationale -Page 37 PermR No. CO-0045675 <br />Comment: Issues Relating to the Impact [o the Rito SecdSurface WatersrOownstream: <br />- Issues related to water quality data (suAace sampling locations utilized, hardness values, seasonal consideraf <br />low Oow determination, etc.) <br />- Concerns regarding the impact of the facility's discharges upon water quality in the Rito Seco, water drawn for <br />and other agricultural purposes, drinking water supplies (alluvial and ground water) downstream of the vicinity, and <br />ground water downgradient of the facility <br />- Concern regarding potential impacts to exisb'ng Watershed projects in the area. <br />- Assessment of an instream point of compliance <br />Vlll. CHANGES TO PERMIT AND RATIONALE FOLLOWING PUBLIC NOTICE <br />First Public Notice Period, Comment Letters and First Public Meeting• (Cont.): <br />Responses to Comment Letters: (Coot) <br />Comment: Issues Relating to the Impact to the Rico SecdSurlace Watersrpownstream: (Cont.) <br />Responses: <br />The proposed CDPS discharge permit will be protective of the classified uses (for recreation, aquatic life, agriculture, and <br />drinking water uses) and the water quality standards that exist /or the Rito Seco. In fact, due to the antidegredah'on-based <br />limits, the permit will be generally much more protective with resMclive limits that are often much lower than the water <br />qualify standards and/or drinking water MCL values, Appendix C shows a comparison between the antldegradation-based <br />limits antl the water quality standard-based limits for outfall 001b. <br />With attainment of antidegredab'on-based limttafions and water quality standard-based limttations and prevention of <br />discharges at 002 from the West Pit in this COPS permit, there will be no adverse impacts fo existing Watershed projects <br />in the area. Also, this should enable a centering of attention to other projects in the area which would be more critical to <br />address. <br />Specific issues relating to surface water qualify are further discussed in Appendix D, <br />Comment: Other Issues: <br />- Recommendations that the BMRI sformwater discharge permit should tie reevaluated <br />- Submittal of discharge monitoring report data to adddional entities <br />Responses: <br />Stormwater: The current draft of the CDPS permit was developed in support o(the currently actlve implementation of <br />reclamation and remediation activities in the West Pit. BMRI currently holds a stormwater permit and has met all of the <br />reporting requirements o/the stormwater permtt. Stormwater is not part of the application for this COPS permit currently <br />under consideration by the CDPHE. WQCD staff have reviewed the stormwater management plan submitted by BMRI (or <br />their existing general stormwater permit. <br />Discharge Monrloring Repoli Submission: The Division does not require permittees to submit extra copies of discharge <br />monitoring reports (DMRs) to additional entities other than to the Division and EPA. However, BMRI has indicated that <br />they are willing to submit an additional copy o(the DMRs to a local entity, San Luis Water and Sanitation District. <br />Don Holmer <br />August 1, 2000 <br />VILA CHANGES TO PERMIT AND RATIONALE FOLLOWING SECOND PUBLIC NOTICE <br />Second Public Notice Period, Comment Letters and Second Public Meeting: The Battle Mountain Resources Inc. <br />(BMRI) revised draft discharge permit and rationale went to public notice a second time on August 4, 2000. The following <br />comment 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 discussed in the <br />paragraphs below. <br />Environmental Protection Agency, Region VIII, dated October 2, 2000 <br />Costilla County Conservancy District (CCCD) and People's Alternative Energy Services (PAES) -submitted by Lon <br />