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, 08/J1/00 THU 1J:41 FA.T ~~~• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY `~_ ~ REGION a 09918^` STREET -SUITE 300 DENVER CO E0202.249a http JAwww.ep~.gov/reg bn08 AUG 3 12000 Ref: BP-W-P Dave Akers, Section Manager Water Quality Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Dear Mr. Akers: This letter constitutes EPA's initial general comments on the draft CDPS Permit Number CO-0045675 to Battle Mountain Resources, Inc.Battle Mountain Gold Company. EPA Region VIII received the drag permit on August 4, 2000. Don Hohner of your sta$'rcquested EPA provide general comments to the Division prior to the September 6, 2000 Public Meeting on the draft permit. These wmments are only general comments and EPA will decide to submit more detailed comments or an objection to the draft permit pursuant to 40 CFR §123. t4 prior to October 3, 2000, the end of the extended public comment period. At this time, EPA does not believe the draft permit and rationale contain sufficient w.ntrols (el~luent .limitations and monitoring) and/or best management practices (BMPS} to ensure that water quality standazds in the Rito Seco will not be exceeded for the discha, ges from Outfall 002. Specifically, the draft pemtit lacks an appropriate compliance location that includes numeric water quality based eflluent limits for discharges at Outfall 002, and monitoring to demonstrate compliance with those limitations. In our written comments and further diswssions with CDPHE on the previous draft permit for this facility, EPA expressed simile[ wttcerns with regard to Outfall 002. EPA suggested that a compliance location be developed for Outfall 002 which could demonstrate water quality standards in the Rito Seco would be protected. EPA also indicated that a combination of groundwater and surface water pollutant monitoring would be required to ensure compliance at that location. Our previous wmments are given below: "EPA is also concerned about the lack of a distinct point of compliance ;end absence of pollutant monitoring for discharges from Outfall 002. We believe one approach that could be used in this situation is an in-stream point of compliance at an appropriate location below Outfs11002 which would demonstrate compliance with the standards. In the draft y~uut ~PAntad on Racydad Papar