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The seeps were emanating from a part of the facility that did not include any milling or beneficiation operations and did not include any waste from those processes. In fact, the seeps were a result of the naturally-occurring groundwater flowing through the waste rock in the backfilled West Pit. The only technically feasible way to eliminate the seeps was to pump the water out of the ground before it reached the Rito Seco. Once pumping began, the water then had to be managed. There was no alternative for managing the water but to discharge it to the creek after going through amechanical/chemical treatment process. Battle Mountain's original permit application included a request to permit Discharge Point 001 IDP0011, which is the discharge from the treatment plant after treatment. The original draft permit for the facility imposed effluent limits on the discharge from the treatment plant which are more strict than those required for publicly-owned treatment works in the San Luis Valley. Specifically, the permit is written so that the resulting effluent from DP001 does not degrade the quality of the water in the Rito Seco based on data from prior to the initiation of mining operations by BMRI. This policy, at the state and federal level, is the Antidegradation Policy and is rigorously followed by the WOCD in issuing permits. With respect to Discharge Point 002 IDP0021, Battle Mountain's permit application requested a permit for the seepage front because there was in fact a discharge to Surface water. However, the intent of the water management program outlined in the permit application was to eliminate the discharge to the Rito Seco. In the course of writing the permit, the response actions initiated by Battle Mountain had the predicted effect, which was to eliminate the surface seeps. DP001 became the primary management nexus for the water. The commentors noted that the DP002 was not clearly described, and that CDPHE did not propose any controls for the discharges associated with DP002. In the permit application, DP002 was characterized as a seepage front. At that time, the seepage front had a groundwater component and a surface water component. With the elimination of the seeps to surface water, the controlling permit for DP002 is the permit issued by DMG. DMG has, as part of its permit, a groundwater compliance point, at which the effect of the discharge on the groundwater is monitored. The DMG permit requires on-the-ground responses to remedy the impacts, if found. In order for Battle Mountain to comply with the terms of the DMG permit, the company designed and implemented a program, identified in Technical Revision 26 lTR-0261• This document is a condition of the DMG permit and forms the basis for remedial actions including the responses that Battle Mountain has implemented as of this date. The primary response action for protection of groundwater and surface water was designed and evaluated in TR-026. Both agencies have reviewed TR-026 and determined that the response, along with treatment of the discharge through DP001 is a complete and technically appropriate program that meets the objectives of protecting the Rito Seco and the public health, Although this is an extremely complicated issue, the agencies have coordinated permits throughout the process and find that the combination of controlling the outflow through a series of pumping wells, treating the water to remove the concentrations of constituents which are related to West Pit and Rito Seco alluvial groundwater, along with extensive monitoring and reporting, provide multiple layers of environmental and public health protections. Comment: The permit should be issued to both operator (Battle Mountain Resources, Inc. - or "BMRI") and owner (Battle Mountain Gold Companyl. Response: In strict accordance with the Colorado Discharge Permit System Regulations Rule 61.4111, the original permit application for the facility identified BMRI as the applicant because BMRI owned the land, BMRI employees operated the facility and BMRI is the permittee on virtually all other permits which have been in place for the facility since its initial construction. However, as BMRI has indicated in discussions with the WOCD throughout this process, Battle Mountain is committed to a satisfactory technical resolution of the West Pit issues and will respond to such comments by amending its application to reflect bath entities as co-permittees for the facility. An amended applicant identification information will be submitted. Comments: Issues related to outfall 001: The basis for determining the antidegradation review/antidegradation limitations (using Station RS-5 vs. RS-1 or RS-21 Including limitations and monitoring for aluminum Itor 001 and 0021 Concerns related to radioactive constituents in the wastewater sources and the discharges 1001 &0021 Defining the initial and later time periods for the discharge (for 001 and 002) Response: Antidegradation: Several letters contained comments regarding the antidegradation review and the antidegradation- based limitations. BMRI commented that antidegradation should not apply for this permit. The Division has determined that the antidegradation-based limitations in this permit are still applicable, since the discharge will be occurring for a longer term (more than one yearl, and this is not a temporary activity. Other comment letters stated that the baseline should be determined from data at Rito Seco Monitoring Station RS-1 and/or RS-2, rather than Station RS-6. The Division has reevaluated the data and conditions associated with each of these three surface water sampling stations, and determined that the RS-1 location is not a representative area far a baseline assessment. The Division also determined the baseline loading for both of the downstream stations RS-2 and RS-5