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Appendix D, Comment Letters and Public Meeting: BMRI Cwmnents (Cont.) Page 4: 10. V!. Ternu and Conditions of Permit, Tables /V-/a, /a, and /c -Effluent Limitations, Discharge Points The column labeled "Rationale" should clarify which of the standards were water quality based or antidegradation based. Again, with these three ta6fes, BMRI asserts that the WAD cyanide, mercury and silver have no potential for discharge and therefore should be eliminated from the effluent list. Response: The tables have been clarified. For the Nree parameters, refer to previous response for cornrnent I.a. on page 1 oJAppendix D. 11. The table included in Section V/. Terms and Conditions of the Permit, Determination ojefjluent limitations, pollutants limited by water quality standards lras t/re nvo right columns mislabeled. The labels should be reversed. Response: The table has been corrected. l2. V/.8.4. (d) Antidegradation Review BMR/ believes it is inappropriate to apply the antidegradation review process to this program given that it is, in fact, finite and short-term in nature. 77re entire premise of TR-026 is to provide a short-teen management program followed by a long-term program that ultimately includes a re-establishmen[ of the hydraulic connection xith the Rito Seco. It is BMR/'s opinion that an antidegradation review is neither necessary, nor appropriate under applicable regulations. /n its discussion of the applicability of the antidegradation review procedure, the Division asserts that, "based on available data, the resulting antidegradation-based effluent limitations are determined to be reasonably related to the economic, environmental, public heals/r and energy impacts m the public and affected persons. "BMRI finds no apparent relationship ro any of the antidegradation criteria as discussed below. With respect to the economic impacts, BMRI has calculated the Capital and Operation and Maintenance (O&M) costs associated with the long-tern treatment requirements based on the 400 gallons per minute (gpm) treatment capacity. The treatment system selected is membrane separation, which is the best available technology for the sulfate and manganese. These costs also reflect t/re likely scenario for trearrnent during the rer[arnation period as currently defined. Final treatment costs ore those costs incurred for capital construction and O&M as projected by the operator over the planned period of treatment. The capital cost is based on the 400 gpm scenario because BMRI is required to have that treatment capacity under 7R-026. Capital costs are anticipated to be at leas! $1,545,840 plus additional construction costs. O&M costs are $6.90 per 1000 gallons. /t is BMRI's opinion as an "affected person ", that the economic impacts to BMRI are significant and substantial and have no apparent relationship to the potential benefit to the environmen[ or public health. Secondly, BMR/ xis/res to emphasize that the secondary drinking water standards are set only for reasons of aesthetics, including staining, taste and odor. /hose standards are not enforceable by EPA as drinking water standards, and if levels exceeding the manganese and sulfate secorulary standards are found in public water supply systems, those systems are NOT required to treat for those parameters. There is documentation in the USEPA's own li[erature that an estimated 3% of the public drinking water systems in the country have sulfate levels of 250 mg/L or greater. Again, the treannent costs for meeting secondary drinking x•ater standards in the Rito Seco do not bear a reasonable relationship to the classified use. Based on the screening level risk assessment included in TR-026, there are NO adverse impacts to human lrealrh ar the environment from either manganese or sulfate. Thus, no benefit is derived from requiring treatment to meet antidegradation-based standards. Finally, dre energy requirements of the [reatment system are significant and constitute an adverse environmental impact. Response: The Division has deternrined t/rat sire antidegradation-based limitations in this permit are still applicable, since this will be occurring for a longer term (more than one year), and this is not a temporary activity. The Division is xalling to consider economic, environmerrtol, public health and energy impacts as related to this facility; /rowever, much snore information x~ould need to 6e submitted before the Division could evaluate the economic aspects. Also, since sire proposed antidegradation-based limits have been attained at the wastewater treatment plant, these limits appear to be feasible to meet. /j BMRI wants to pursue this Junkier, they should consult xdth the Assessment Unit of the WQCD to determine what additional injonnation would need to be submitted for review.