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J. J. Dudash -2- December 15, 2008 <br />be no more than 2.2 cfs. The culvert is not a highway drainage culvert. It was <br />installed to convey irrigation return flow to the river. The culvert no longer handles <br />irrigation water. Therefore, the culvert will have adequate capacity to handle the <br />mine water flow. <br />4. DRMS - Please add a discussion to the permit application text that describes <br />whether or not there are any lands, river banks, structures, alluvial valley floors or <br />prime farm land on either side of State Highway 133 that potentially may be <br />adversely affected by the mine water discharge quantity or quality. If so, how will <br />BRL mitigate such potential effects. Please include in your discussion the <br />possibility of additional sediment entering the North Fork of the Gunnison River <br />due to erosion.. <br />BRL - See amended page 2.05-70. <br />5. DRMS - The Division understands that BRL is in the process of applying for a <br />revision to the NPDES permit to change the location and the rate of flow for the <br />mine water discharge point 006 as described in TR-54. Please provide a copy of <br />the revised NPDES permit when it is obtained. <br />BRL - The amended NPDES permit is enclosed. <br />6. DRMS - On proposed page 2.05-69, the water analyses presented were based on <br />water that came from the B-8 panel headgate. The Division would like to know if <br />the water sample was taken before or after the water entered the underground <br />sump. If the sample was taken before the water entered the underground sump, <br />please explain why BRL believes that there would not be any difference in the <br />water quality of the sample if it had been sampled after it had entered the <br />underground sump. <br />BRL - The addition sampling and analysis shown on pages 2.05-69 and 2.05-70 <br />should satisfy the DRMS' concerns. <br />7. DRMS - Please provide a description in the permit application text that explains <br />the process of discharging mine water when the underground sump is being <br />cleaned out. <br />BRL - The underground sump is an abandoned longwall panel. It will not be <br />cleaned. <br />8. DRMS - On revised page 2.05-69, the mine water analyses presented do not <br />include all of the chemical constituents listed in the NPDES permit for mine water <br />discharge outfall 006. Please revise the mine water analyses on page 2.05-69 to <br />include all of the chemical parameters that will be listed in the soon to be revised <br />NPDES permit and provide a complete copy of the laboratory analyses to the <br />Division.