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The Environmental Protection Agency's (EPA) Concerns: <br />The EPA submitted comments to the State regarding this discharge permit on <br />August 31, 2000. Here are a couple of exerts from those comments. These are <br />direct quotes from the EPA's letter to the State. <br />" At this time, EPA does not 6~elieve the draft permit and rationale contain <br />sufficient controls (effluent limitations and monitoring) and/or best <br />management pra~etices (BMPs) to ensure that water quality standards in the <br />Rito Seco will not be exceeded! for the discharges from outfa11002:' <br />"Specifically, the draft permit lacks an appropriate compliance location that <br />includes numeric water quality based effluent limits for discharges at 002, and <br />monitoring to demonstrate compliance with those limitations:' <br />"EPA is...concerned about the lack of a distinct point of compliance and <br />absence of pollutant monitoring for discharges from outfall 002." <br />"EPA believes the division has defined the seepage front (outfall 002) as <br />requested, however, the extent of the seepage front encompasses a much wider <br />vertical and lateral extent than EPA envisioned in the review of the previous <br />draft permit and discussions with CDPHE and Battle Mountain Resources, <br />Inc. Because of the complex !hydrological conditions of the area, EPA does not <br />believe ithat water level monitoring in one monitoring well (BF-4) and its <br />relation to the proposed elevation "trigger" of 8583 ft. amsl, is sufficient to <br />demonstrate the presence or absence of discharge to the Rito Seco along such <br />a large :seepage front " <br /> <br />