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COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br />Rationale -Page 22 Perntit No. CO-0045675 <br />V///. CHANGES TO PERM/T AND RAT/ONALE FOLLOW/NG PUBL/C NOT/CE <br />Public Notice Period, Comment Letters and Public Meeting: (Cont.): <br />In addition to the above comment letters most of which also requested a public meeting, there were approximately 30 m 35 fevers <br />Jrom individuals requesting a public meeting on this discharge pennit. TTre public meeting was held on June 27, 2000 in San <br />Luis, Colorado. <br />Issues Indicated in Public Comment Letters: <br />The follox~ing topics were addressed in the cormnent levers: <br />Issuing the permit to both operator (Battle Mountain Resources, Inc.) and oxmer (Battle Mountain Gold Company) <br />Issues related to outfal[ 00/: <br />- The basis for determining the antidegradation reviex~/antidegradation limitations (using Station RS-5 vs. RS-! or RS-2) <br />- Including limitations and monitoring for alteminum ((or 001 and 002) <br />- Concerns related to radioactive constintents in the Aischarge ((or 00/ and 002) <br />- Defining the initial and later time periods jar rlre discharge <br />Issues related to outfall 002.• <br />- Better definitions jar the location and requirements jar outfall 002 <br />- Utilizing monitoring wells to define outfa[l 002 <br />- Addressing specific flow and other limitations and monitoring requirements jar outfal[ 002 <br />- Identifying seepage contributions as part ojrhe mass balance water quality standard-based calculations <br />- Not referencing the CDMG requirements jar TR-26 and TR-28 in association with the requirements jar attfall 002 in the CDPS <br />discharge permit <br />- Concerns related to slmn-term West Pit groundwater discharge issues and long-term water groundwater discharge issues <br />(defining a window far identification ojground water flowing through a restricted zone as a point ojcomp/lance; utilization of <br />additional ground water monitoring wells; installation of a slurry x•all) <br />- Concerns regarding the Best Management Practices requirements described jar outfa[l 002 <br />Including additional outfalls (or discharge points), limits, and monitoring jar the four surface seeps; ensuring that the seeps are <br />contained and rill not discharge [o surface waters <br />Other Groundwater Related Issues: <br />- Concerns xdth the mining operation and reclama[ion activities impacting the ground water hydrology in the vicinity <br />- Impacts upon wells dorengradient of the facility <br />- /rrdicalions of locations ojdrinking x~ater sources in the vicinity (Slralorn Ranc/r, San Luis alluvial wells, etc.) <br />Issues Relating m the Impact to the Rim Seco/Surface Waters/Downstream.• <br />- Issues refaced to water quality dam (surface sampling locations u[iliZed, hardness values, seasonal considerations, stream low <br />Jlow determination, etc.) <br />- Concerns regarding the impact of the facility's discharges upon water quality in the Rito Seco, water drawn for irrigation and <br />other agricultural purposes, drinking water supplies (alluvial and ground water) downstream of the vicinity, and ground water <br />downgradient of the facility <br />- Concern regarding potential impacts to existing Watershed projects in the area. <br />- Assessment of an instream paint ojcornp[iance <br />Other Issues: <br />- Recommendations that the BMR! stormx•ater discharge permit be reevaluated <br />- Submittal of discharge monitoring report data to additional entities <br />/slues Indicated in the Public Meeting: <br />A public meeting x~as held to discuss this permi[ by the Division (with the coordination and assistance of rlre Castilla County <br />Commissioners) on June 27, 20100 in San Luis, Colorado. A number of mmmemts were received during the public meeting from <br />many individuals. This list ojcomments is too extensive to include in this section of the rationale, but a surmnary of the questions, <br />issues, concerns, and comments raised at the meeting is included in the attached Appendix E. The Division has reviewed and <br />considered the issues discussed in the public meeting x•i[/r respect to making changes jar this pennit and rationale. This permit is <br />again being submitted jar public notice reviex• on August 4, 20100 for a thim day period. <br />