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conducted at both surface water and groundwater locations. The monitoring plan <br />will be submitted under sepazate cover. <br />BMRI and its technical experts concurred with the comments of Mr. Bruce <br />Mazshall, Rocky Mountain Consultants, Inc., set forth in a letter dated April 20, <br />2000, which stated that, in his professional opinion, "issuance of this document is <br />premature." Therefore, TR-28, which addressed long-tern- water quality in the <br />West Pit, was withdrawn from consideration by DMG at the request of BMRI. <br />Comment: <br />V-Aluminum: <br />Response: <br />The basic standard for aluminum is dissolved. If a total concentration were used <br />to screen for the reasonable potential for aluminum, aluminum would likely be <br />assigned effluent limitations in every CDPS permit. Aluminum was considered <br />during the development of the permit. Appendix A to the Rationale presents data <br />for aluminum from the pit backfill, alluvial pumping wells, and seeps. As stated <br />in the draft permit, the initial detemunation was made that a permit limit for <br />aluminum would not be applicable. BMRI and its technical experts believe that <br />there is no reasonable potential for aluminum to be dischazged from the water <br />treatment facility, and therefore, contend that the original determination regarding <br />the exclusion of aluminum as an effluent limitation was correct. <br />Ba(!!e ,NounlQin Rerources, Inc. HS! GeaTrans <br />() July71, 7000 <br />