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and downstream locations would be the highest annually. Greater natural loading <br />would probably occur during the spring snowmelt when the flows aze greatest and <br />concentrations aze typically at annual low values. Therefore, the permissible <br />constituent loading calculated will be conservatively low. <br />Comment: <br />6. Section III.B.2, page 3 <br />The permit provides no information concerning the calculation of the lE3 and <br />30E3 low flow values. Specifically, what station were these values derived from? <br />How many flow values were used in the calculations? What is the period of <br />record (e.g., does it include a mixture of "wet", "dry", and "normal" yeazs)? <br />Absent this documentation, the applicability of these flow values as the lE3 and <br />30E3 low flow values can not be justified. <br />Response: <br />No comment. The determination was made based on an evaluation conducted by <br />the CDPHE-WQCD. <br />Comment: <br />7. Section III.B.3, page 3 <br />The Shalom Ranch Headgate is located less than 5 miles downstream of the <br />facility. <br />Response: <br />The Shalom Ranch Headgate diverts water from the Rito Seco for agricultural <br />use. A comparison of the historical water quality data record for the Shalom <br />Ranch Headgate and the surface water station RS-5 (data that aze in the CDPHE <br />files) show that the water quality at the Shalom Ranch headgate generally mirror <br />the quality of water as measured at RS-5. <br />Battle Mountain Resources, lnc. HSl GeoTrans <br />19 Jnry zl, zooo <br />