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r TRAPPER MINING INC. COMMENTS -DRAFT NPDES PERMIT CO-0032115 I. RATIONALE -TABLE II-1 1. Outfall 001. Source should be changed to include spoil spring(SS). This spring developed in late 1993, resulting in continual discharge at outfall 001. 2. Outfall 002. Receiving water is M. Pyeatt Gulch vice W. Pyeatt Gulch 3. Outfall 011. Source should be changed to delete spoil spring (SS). This spring has not discharged since the late 1980's. 4. Outfall 015. Receiving water should be designated as Grouse Gulch vice Flume Gulch. R. TERMS & CONDITIONS 1. Part A Paragraph 4, Salinity Parameters Why was this parameter added to Trapper's monitoring scheme? This has oot been a part of Trapper's sampling program since the mina start-up. This requirement should be removed. III. MONTTORING REQUIREMENTS 1. Part B Paragraph 1(b) Settleable Solids, mgfl has been left out as an effluent parameter. This should be included. 2. Part B Paragraph 2 - Special Conditions - Outfalls 005 and 011 Seep flow data for outfall 011 should be removed as this seep no longer exists. This is compatible with the change in Table II-1. 3. Part B Paragraph 4 -Acute WET Testing In Trapper's current NPDES Permit, the acute WET testing for outfall 002 is "...the monitoring frequency for acute WET tests shall be semiannually with alternating species, with testing for fathead minnows during the first six-month period and with Ceriodaphnia species for the second six-month period of each year." Trapper's permit was amended by the Department, June 8, 1993, to reflect this monitoring change. This change was the result of a waiver requested by Trapper, December 28, 1992, based on the successful completion of WET testing at this outfall. This modification should be allowed to continue for Outfall 002. No WET test failures have been reported at this outfall. LWH/mg/CDH-217