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Comments: Including additional outfalls for discharge points), limits, and monitoring for the four surface seeps; <br />ensuring that the seeps are contained and will not discharge to surface waters <br />Response: <br />No additional outfalls need to be identified in this permit for the four historic surface seeps, since there has not <br />been flow in any of the original seep locations since February 8, 2000. This has also been further addressed under <br />the requirements }or outfall 002. <br />Comments: Other Groundwater Related Issues: <br />- Concerns with the mining operation and reclamation activities impacting the ground water hydrology in the <br />vicinity <br />- Impacts upon wells downgradient of the facility <br />- Indications of locations of drinking water sources in the vicinity (Shalom Ranch, San Luis alluvial wells, etc.) <br />Response <br />Issues relating to groundwater are addressed in the Colorado Division of Minerals and Geology ICDMGI mining <br />permit for this facility, since impacts to groundwater from the mining operation are under the jurisdiction of that <br />agency. Also, this has been further addressed under the requirements for outfall 002. <br />In addition, with protection of surface water quality standards through compliance with the limitations for this <br />permit, the applicable groundwater standards would also be protected. <br />An indication of the concerns relating to the locations of the downgradient alluvial/groundwater drinking water <br />sources (wells) have been previously included in that portion of the rationale. <br />Comment: Issues Relating to the Impact to the Rito Seco/Surface Waters/Downstream: <br />- Issues related to water quality data Isuriace sampling locations utilized, hardness values, seasonal <br />considerations, stream low flow determination, etc.) <br />- Concerns regarding the impact of the facility's discharges upon water quality in the Rito Seco, water drawn for <br />irrigation and other agricultural purposes, drinking water supplies )alluvial and ground water) downstream of the <br />vicinity, and ground water downgradient of the facility <br />- Concern regarding potential impacts to existing Watershed projects in the area. <br />- Assessment of an instream point of compliance <br />Responses: <br />The proposed CDPS discharge permit will be protective of the classified uses (for recreation, aquatic life, <br />agriculture, and drinking water uses) and the water quality standards that exist for the Rito Seco. In fact, due to <br />the antidegradation-based limits, the permit will be generally much more protective with restrictive limits that are <br />often much lower than the water quality standards and/or drinking water MCL values. Appendix C shows a <br />comparison between the antidegradation-based limits and the water quality standard-based limits for outfall 001 b. <br />With attainment of antidegradation-based limitations and water quality standard-based limitations and prevention of <br />discharges at 002 from the West Pit in this CDPS permit, there will be no adverse impacts to existing Watershed <br />projects in the area. Also, this should enable a centering of attention to other projects in the area which would be <br />mare critical to address. <br />Comment: Other Issues: <br />- Recommendations that the BMRI stormwater discharge permit should be reevaluated <br />- Submittal of discharge monitoring report data to additional entities <br />Responses: <br />Stormwater: The current draft of the CDPS permit was developed in support of the currently active implementation <br />oT reclamation and remediation activities in the West Pit. BMRI currently holds a Stormwater permit and has met all <br />of the reporting requirements of the Stormwater permit. Stormwater is not part of the application for this CDPS <br />permit currently under consideration by the CDPHE. WOCD staff have reviewed the Stormwater management plan <br />submitted by BMRI for their existing general Stormwater permit. <br />Discharge Monitoring Report Submission: The Division does not require permittees to submit extra copies of <br />discharge monitoring reports (DMRsI to additional entities other than to the Division and EPA. However, BMRI has <br />indicated that they are willing to submit an additional copy of the DMRs to a local entity, San Luis Water and <br />Sanitation District. <br />