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.. COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division Rationale - Page 15 Permit No. CO-0043168 VII. REFERENCES A. Colorado Dept. of Health, Water Quality Control Commission. Bas"c Standards and Methodologies for Surface Water (3.1.0). Denver: CDH, as revised 10/8/1991. B. Colorado Dept. of Health, Water Quality Control Commission. Reeulations for Effluent Limitations (10.1.0). Denver: CDH, as revised I/31/1990. C. Colorado Dept. of Health, Water Quality Control Commission. Reeulations for the State Discharge Permit Svstem (6.1.0). Denver: CDH, as revised 1/6/1992. Don Holmer April 14, 1992 VIII. CHANGES FOLLOWING PUBLIC NOTICE Two comment letters were received during the public notice period. One letter was from David A, Pampu, the Deputy Executive Director of the Denver Regional Council of Governments (DRCOG). in this comment letter dated May 20, 1992, DRCOG indicated that the proposed effluent limits are protective of surface water resources downstream of the segment 13 discharge point. Ir. the letter from the permittee {from Steve Schurn~anl dated Jure 1, 1992, s<_:veral comments were made. The Division made some changes to the rationale and the permit, based in part upon this comment letter. The changes made to the permit include an increase in the initial discharge flow of 0.576 MGD (or 400 gpm) for the first three months (on page la) and the addition of footnote o/ (on pages lb and 4) for the potentially dissolved metal analysis. No other changes were made to the permit. The changes made in the rationale include a correction for the owner (on page 1), the increase in the initial discharge f:Low of 0.576 MGD for the first three months (on pages 1, 2, 5, 6 and 8), and the discussion in this section (Part VIII of the rationale), Another item discussed in the permittee's comment letter was that "the water treatment plant at the Bates Hunter mine has been developed and constructed by the mine owners. Bench tests and ongoing pilot tests conducted by the mine o+mers have shown that excellent constituent discharge levels, in many cases significantly lower than the required discharge levels, have been obtained with the Bates Hunter water treatment plant." One other comment from the permittee was that "as the owners have developed and constructed the watez treatment plant, the owners of the Bates Hunter mine do not feel that operator certification is required for the water treatment plant." However, industrial wastewater treatment plant operator certification is required per section 25-9-100.9.5 of the State R~ulations for Certification of Water Treatment Plant and Wastewater Treatment Plant Operators. A copy of these regulations has been sent to Steve Shurman.