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there is no source of groundwater flow for which water quality standazds could be <br />set. <br />BMRI will maintain the groundwater level in the West Pit sufficiently low to <br />ensure that the current no-outflow condition prevails throughout the period of the <br />CDPS permit. During the period of reclamation and remediation in the vicinity of <br />the West Pit, any proposed change in groundwater levels to be maintained in the <br />West Pit would require review and approval from CDPHE. <br />Comment: <br />IV-Other Potential Water Oualiri Based Effluent Limits: <br />Response: <br />As noted previously, the primary BMP identified in the TR-026 water <br />management plan is the reversal of the hydraulic gradient to eliminate the flow of <br />groundwater from the West Pit into the adjacent Rito Seco alluvial aquifer. The <br />water level in the West Pit has been lowered sufficiently to reverse the hydraulic <br />gradient at the vicinity of the West Pit. Thus, the West Pit will not serve as a <br />source of dischazge from Outfall 002 during the CDPS permit period. Therefore, <br />BMRI believes that the appropriate compliance condition for Outflow 002 during <br />the period of active reclamation and remediation in the West Pit would be to <br />maintain the groundwater level sufficiently low to maintain the hydraulic gradient <br />reversal. <br />Associated with the implementation of the TR-026 water management plan and <br />the BMP for the CDPS permit is a monitoring program that would provide the <br />information necessary to verify that the groundwater system has responded as <br />projected. BMRI has implemented an approved performance monitoring program <br />(DMG) in conjunction with the TR-026 water management program. The <br />performance monitoring program consists of a combination of groundwater level <br />monitoring with water quality monitoring. The water quality monitoring is <br />Baflk Maunmin Resources, Inc. HSl Georrans <br />$ July ll, 7000 <br />