HYDRO29057

• Permit No: M1988112
• IBM Index Class Name: Hydrology
• Doc Name: TABLE OF CONTENTS
• Media Type: D
• Archive: No

Appendix D, Comment Letters and Public Meedng.• BMRI Cormnents (Cont.) Page 2:
2. Pan / - Effluent Limitations - Besr Management Practices (BMPs) -Discharge Point 002
!t is BMR!'s intent to fulfil! all of its obligations as estab[islred by the Division ojMinerals and Geology (DMG), as well
as the Colorado Department ojPublic Health artd Environrrrent (CDPHE) t/rroughoret the life ojthe reclamation period.
While active reclamation is in being conducted, BMRI intends to follow the BMPs as described in the referenced
section. However, a fundamenml premise of dte response plan approved for the site in TR-026 is m re-establish the
hydrologic connection between t/re West Pit and t/re Rita Seco alluvial aquifer once the approved West Pit rernediation
activities have been completed and accepted by DMG. At drat paint, there will no longer be an obligation to provide
treatment or monitoring of the groundwater beyond the camrnimrents made in the DMG dacumen[s (TR-026).
Response: /n addition to the above corrrment from BMR/, the Division and BMR! later have determined to redefine the
applicable requirements for discharge point 002. T/ris includes defining 002 with respect to maintaining a water level
depth in the West Pit that is belox~lhe water level ojthe Rito Seco to ensure that the hydraulic gradient is reversed
resulting in discharge going to the Rito Seco from the West Pit. A compliance schedule lots also been incorporated into
the permit to funkier address the existing situation if furore seeps from the West Pit should occur. Refer to the revisions
for 002 and the compliance schedule for funkier injornmtion.
3. D. Special Requirements -Materials Containment Plan
The jaciliry currently is required by DMG to implement a spill prevention control and countermeasures plan (SPCC),
which has been submitted to DMG. The document is Technical Revision 27 (TR-2~ and includes those requirements
for the Materials Containment Plan as well. A copy of the document, along x~ith the Ernergenry Response plan, is
attached to these comments.
Response: T/ris document has been placed in the perm[ file. This submission satisfies the permit submittal requirement
for the Materials Containment Plan.
4. Pan lI -Notification Requirements -Change in Discharge
The Water Quality Control Division is requiring notification and an evaluation of the effects of any change in the
discharge. BMRI is obligated to make those same not cations and evaluations to t/re DMG xdth respect to any changes
that will aJj'ect the groundwater quality or quantity. We are hig/tlighting this to illustrate the efj'ects of the dual
jurisdiction asserted by both agencies over the scone resource. BMR/ /vas been and will continue communicating with
both agencies during the reclamation period and will continue to highlight areas of dual jurisdiction so that the
agencies may provide effective regulatory coverage, rather than duplicative coverage.
Response: The WQCD xdll continue to x~ork x~th BMR/ and COMG on these issues.
5. Part l! -Notification Requirements -Discharge Point
BMR/ would note that its entire facility is explicitly covered under the Colorado genera! permit for stonnwater
discharges (Permit No. COR-040050) which authorises discharges ojstormwater from the jaciliry. Therefore the
prohibition in paragraph 8 should be qualified to exempt stonnwater discharges.
Response: This potion ojtlte permit (on page 25) has been accordingly revised.
6. Part /l -Notification Requirements -Minimization of Adverse Impacts
BMRI is required by this provision to take all reasonable steps to minimize or prevent violation of this permit which /vas
a reasonable likelihood of adversely affecting /roman health or r/te environment. We xdsh to highlight t/rat this
discharge, even uncontrolled xdll have no adverse affect on /roman health or the environment. The risk assessment
included in TR-026 clearly demonstrates drat there has not been and would probably never be, an adverse affect as a
consequence ojdie diselearges associated x7de the backfrlled West Pu.
Response: No comment neressarv, other than BMR/ should continue with operations to comply with this discharge
permit.
Rationale Comrnetrts
/l. Facility Information - Hardrock Mining (in closure and remediation)
T)te facility is nor actually a mine dnvatering facility, Rather, it is a treatment facility for groundwater located in and
around in the backfilled West Pit.
Response.• Tlris discussion was revised.