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<br />Comment: <br />17. Section VI.A.2, page 12, fourth full paragraph, last sentence <br />As discussed in Comment Number 8, the permit is incomplete without having the <br />TR-26 (and TR-28) documents attached. And, because TR-28 has not been <br />approved nor passed the DMG's adequacy review, it should not be used as a basis <br />for this permit. <br />Response: <br />See response to Comment Number 8. TR-028 has been withdrawn by BMRI. <br />Comment: <br />18. Section VI.A.2, page 12, last oazagranh <br />Monitoring data collected as part of the West Pit monitoring system should be <br />provided on a more routine basis than the annual requirement specified in this <br />section. An annual report should still be required, but more frequent reporting <br />(i.e., monthly) of surface water and groundwater monitoring data is certainly <br />warranted. <br />Response: <br />The DMG receives monthly reports of the water quality data collected as part of <br />the TR-026 performance monitoring program. Thus, the data aze available and <br />part of the public record. The groundwater level elevation data from the <br />backlilled West Pit constitutes the most pertinent information that measures the <br />status of the system. Groundwater level information is also communicated to the <br />DMG on a monthly basis and BMRI would propose to submit the results of the <br />performance monitoring program on a mont}ily basis to the CDPHE as part of the <br />CDPS permit in lieu of an annual report. <br />Comment: <br />19. Section VI.A.3, page 13, mass balance analysis <br />The mass balance analysis ignores any loading to the surface water system from <br />the seepage front. The permit must account for loading from the seepage front or <br />explicitly state that there is zero allowable discharge from the window to the Rito <br />Battle Mountain Resources. /rtt. HSl GeoTrans <br />24 July?l, 1000 <br />