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SPECIFIC COMMENTS <br />Comment: <br />1. Section II.F, pace 1, second pazaeraph, last sentence <br />Dischazge Point 002 is not shown on either Figures 1 or 2 of the permit. As noted <br />above, Dischazge Point 002 actually consists of at least five separate and discrete <br />dischazges: 002, the window, and 003 through 006, the four separate seeps along <br />the Rito Seco. <br />Response: <br />See the response to the fast comment under the heading GENERAL <br />COMMENTS. <br />Comment: <br />2. Section II.G, pane 2 <br />The duration of the "initial" and "later" time periods for Dischazge Point OOl <br />must be defined. <br />It is implied that the dischazge rates from Dischazge Point 001 will progressively <br />decrease (i.e., 400 gpm to 250 gpm to 110 gpm). This progression must be <br />specified. If there is cause to revert back to a higher pumping rate, it would <br />indicate that the "water management plan" has failed, and the rationale for the <br />permit should be re-examined at that time. <br />There aze no maximum dischazge rate limitations listed for Dischazge Point 002, <br />the location of which is never given. Assuming that it is the seepage front, note <br />that Item 3 on page 1/10 in the August 30, 1999 document CDPS Permit <br />Application: Minimal Dischazge Industrial Wastewater submitted by BMRI, <br />states that pumping of the system at a capacity of 400 gpm will reverse the <br />gradient away from the Rito Seco, thereby eliminating the seepage front. <br />However, from a location along the County Road, Costilla Counry Conservancy <br />District (CCCD) officials observed flow from one of the seeps on the bank of the <br />Rito Seco on April 30, 2000 (M. McGowan, CCCD, electronic common.). <br />In subsequent sections, the permit states that BMP's aze to be used in association <br />with Discharge Point 002, but again does not address the discharge rates from <br />either the window or the springs. We believe that quantification of these flows is <br />important. The applicant estimates West Pit outflows in Section 3.1.4.4 of TR-26. <br />Through monitoring of the water levels in the alluvium, and the utilization of the <br />permeabilities determined from aquifer testing, the applicant should be able to <br />reasonably quantify groundwater flow through the restricted "window". If <br />Ba!!(e Mountain Resources, (nc. H57 Geo I raps <br />13 July 7!, 7000 <br />