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Appendix D, Comments from Rocky Mountain ConsuUants. /nc., Hvdrodinetics, Inc., & Hydrodynamics,/nc. (Cont.) Page 14 <br />Comment: <br />12. Tables VI-la V!-Ib. and V/-Ic anues 9. /0. and 11 <br />The parameters included in there fables should be consistent xith the list ojpararneters presented in Section /!/.A.2, plus <br />aluminum (see Cammen! Number 2). <br />An analysis must be performed to determine that uranium and/or radi«rn are the source ojthe elevated gross alpha activity <br />detected in the West Pit waters. <br />Responses: <br />See the responses to Comment No. 3 on page 11 ojtltis Appendir D. <br />The eJJluent limitations explicitly set limits on the concentrations of uranium and radium dischargedJrorn [he water treatment <br />jacility. <br />Canment: <br />13. Section VLA.2 pate 11. first sentence <br />See comment 11. <br />Response: <br />See response to cornrnent 1l. <br />Comment: <br />14. Section V/ A 2 pates 11 and 12 last sentence on page 11 continuing on page 12 <br />All Parties agree that seepage jrorn the West Pit Itas impacted water quality in the Rito Seco and the Rito Seco alluvium. The <br />ward possibly should be deleted from this sentence. <br />Response: <br />The description and discussion of outfall 002 x•as revised. This particular cotnrnent is na longer applicable since that sentence <br />no longer exists. <br />Comment: <br />I5. Section V/.A.2 ~e 12 second full paragraph <br />The statement that "...it is technically infeasible to establish numeric effluent limitations jor the seepage front" is without merit. <br />See General Comment Number 2 regarding the designation of the xdndow area wells and individual seeps as discharge <br />monitoring points. <br />Response: <br />See response to General Commen( Number 2. Discussion related to this subject has been revised. <br />Commem: <br />16. Section VLA.2. ~e 12 third full paragr~lt, items 1 and 2 <br />The permit needs to define how these two 'plans" relate to the three 'periods" described in II.Gjor Discharge Point 001. <br />The permit needs to identify the timing ojthe two plans and specify, in detail, the conditions that allow BMR/ to switch jrorn the <br />initial to long-term plan. <br />The final statement in /tern 2 that the water treatment systems xd[l be operated "until water management goats are achieved" <br />requires an ertensive discussion. Specifically, the "goals" need to be defined. <br />Response: <br />Portions of this cortunent have been previously discussed in the rationale. The issue of liming described by the reviewers has no <br />relevance to the CDPS permit. The permit sets effluent [imitations jor the tiered flows as specified in the draft permit. BMR/ <br />will be required m conduct water treannent activities such that discharges from the water treatment jaciliry meet the required <br />effluent limitations. <br />The groundwater level in the West Pi[ x•il( be maintained suc/t that the reversed hydraulic gradient conditions prevail for the <br />entire period of the CDPS permit. <br />