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Mr. J. David Holm <br />Water Quality Control Division <br />Page 3 <br />technical resolution of the West Pit issues and will respond to such comments by <br />amending its application to reflect both entities as co-permittees for the facility. <br />Amended applicant identification information for your use in preparing the revised draft <br />permit will be submitted under separate cover. <br />Technical Revision 26 ("TR-26"1 <br />Many of the public comments focused on Dischazge Point 002 and the proposal in the <br />draft permit to regulate this "outfall" through best management practices incorporating <br />the provisions of TR-26. However, it is cleaz that virtually all of the comments, both <br />written and verbal, reflected a fundamental misunderstanding of the requirements of TR- <br />26 and the work which has been completed to date in conformance with those <br />requirements. As stated in the Summary of Rationale, TR-26 is a technical revision to <br />the Colorado Mined Land Reclamation Board ("CMLRB") permit for the mine (Permit <br />No. M-88-I 12. This technical revision has been fully reviewed and approved by DMG <br />on May 23, 2000, and is therefore an enforceable part of the CMLRB permit. TR-26 was <br />developed as part of a response plan implemented by BMG after elevated levels of TDS <br />were identified in the designated monitoring well for the alluvial aquifer downgradient <br />from the West Pit. Your office was consulted frequently in the development, review and <br />approval of TR-26 and copies of all pertinent documents have been submitted to your <br />office and aze included as part of the record which supports the draft permit. In addition, <br />we note that TR-26 has been the subject of extensive public review and, in accordance <br />with a CMLRB Order, CCCD, PAES and Mineral Policy Center representatives were <br />provided with copies of TR-26 and all pertinent correspondence and submittals. <br />TR-26 sets forth a series of response activities that were based on a characterization of <br />the geohydrology of the West Pit and the surrounding alluvial system. These activities <br />were developed to implement a rapid response to the elevated constituent levels in <br />groundwater, monitor the effectiveness of that response and develop longer term response <br />mechanisms in the context of the information gained in the implementation of the initial <br />