Laserfiche WebLink
. , ~~~~ <br />'~~ <br />iii iiiiiiiiiiiii iii <br />UNITED STATES SNVIRONMEN7AL PROTECTION AGENCY <br />REGION 8 <br />9~9 ta'" STREET -SUITE :06 <br />0°_NV:R, CO 80204-2=bc <br />ht!D:Ihvww.epa.govl~eg ionCB <br />MRY - 5 20(x; <br />Ref: 8P-W -P <br />]. David Holm. Duector <br />Water Quality Control Division <br />Colorado Department of Public <br />Health and Envirorunent <br />4300 Chem Creek Drive South <br />Denver, Colorado 80246-] 530 <br />Dear ylr. Holm: <br />This letter constitutes EPA's commentc on the issuance o ~rar? or proposed C:DPS Permit <br />Number CO-004:475 to Battle \9ountain Resources, ]nc. EPA Region VIII received the dra$ <br />permit on March 3 ] , 2000. <br />At this time, EPA does not believe the draft permit and rationale contain sufFcient <br />information to demonstrate the proposed effluem limitations and/or controls (BlviPs) ~:nsure that <br />water quality standards in the Rito Seco will be met for the discharges from Outfalls 04] and 002. <br />Our general concerns are in regard to baseline water quality data used in the <br />antidegradation analysis, lack of specific numeric efiluem limits for iron and manganese for Outfall <br />002, and potemially other appropriate numeric water quality based effluent limitations at Outfall <br />002, and in addition, the lack oflimitations and/or specific wntrols for alumimrm in the discharges <br />from Outfalls 001 and 002. Our concerns are outlined below: <br />Water OuaL+ri Bata in the Antidegradation Analysis: ]t appears that the baseline water <br />quality data used in the anti-dcaradation review for developing eElurnt !imitations for Outfall 001 <br />was from station RS-5. RS-5 is approximately 2 miles downstream from the West Pit Outfall 002 <br />and an additional historic mining impacted area called the "Earth Science Pit". EPA believes a <br />more aCproPriaro bgytl+ne w`'"r quality condition wtntld be derived from station RS-] which is <br />aaoroximntely 2 miles upstream of the Bartle Mountain Honing activity. i he CDPHE rationale far <br />using tFus data- i~in3t~iere are numerous tnoutanes entering the Rito Deco between RS-1 and <br />RS-5 end that these tributaries mate aavrately reflect the ittt]uenc~ of the natural geology near <br />the site. EPA believes these tributaries are comained within the Battle Mountain penttit boundary <br />and additional flow from the Earth Science Pit contnbutes metal toad to this stream: In this <br />respect, EPA does not believe tt:e influences are completely attributable to natural geologic <br />conditions. Furthermore, the baseline hardness value utilized for the calculating the water quality <br />~p10M+A O/l RKyrJW lipr <br />