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identifiable and the sample results initially submitted show that the discharge would meet the <br />effluent limitations for pH and total suspended solids. However, compliance with 4.05.2 and <br />4.05.16(4) requires that the discharge meet all applicable water quality standards or effluent <br />limitations. A discussion is provided on pages 2.05-72 and 2.05-73 regarding potential impacts <br />to the North Fork of the Gunnison River. There may be additional water quality standards or <br />effluent limitations that apply. With TR-54 (pending approval) the effluent parameters <br />associated with BRL's revised CDPS permit were expanded to include additional parameters. <br />These are given on the proposed PHC North Fork of the Gunnison River table page 2.05-73i as <br />submitted with TR-54. The Division believes that these effluent parameters may then be <br />applicable to the mine water discharge proposed with TR-57. Please demonstrate compliance <br />with 4.05.16(4) and ensure that all applicable effluent limitations and water quality standards <br />have been reviewed and that adequate baseline data for the proposed mine water discharge has <br />been collected and analyzed for the appropriate constituents. <br />4. What is the expected water quality of the anticipated flow when it discharges to the river and <br />what impact would this have on in-stream water quality standards? In Item 4 on page 2.05-74 <br />there is no mention of compliance with applicable water quality standards. Please provide an <br />expanded discussion of the estimated impact to water quality of the North Fork of the Gunnison <br />River. If appropriate, provide a revised PHC analysis to show that there would not be <br />exceedances of in-stream water quality standards as a result of the discharge when combined <br />with flow in the river. <br />5. With TR-54 (pending approval), BRL proposes to discharge water directly to the river via a <br />pipeline from the B-I sump. Is it BRLs intention to discharge mine water simultaneously <br />through the old U.S. Steel abandoned mine workings. If so, please address the cumulative <br />impacts of the combined discharges and address this in the PHC accordingly. <br />6. What are the anticipated impacts to groundwater in the permit and adjacent areas resulting from <br />the proposed additional mine water discharge? In the last paragraph of page 2.05-72 BRL <br />states the following "The quality of ground water should not be impacted unless it flows into <br />the mine. The only potential impact the mine will have on ground water is to intercept it in the <br />underground workings." There is no discussion or update to the PHC to describe the effects of <br />the proposed mine water discharge on groundwater quality in the permit and adjacent areas. <br />7. Based on the above comments, please update the approved hydrologic monitoring plan <br />accordingly. The sampling and analysis plan should include provisions for sampling the <br />discharge at the point of discharge on a continued basis. This data will be crucial in verifying <br />the assumptions made regarding compliance with effluent limitations and water quality <br />standards. Please update the monitoring plan with a proposed schedule including parameters <br />and sample frequency for the discharge from the active B-Seam workings. <br />8. On an ongoing basis the metered discharge volume from the B-Seam workings and the <br />associated water quality data should be reported in upcoming Annual Hydrology Reports. <br />2