Laserfiche WebLink
Dudash <br />Page 2 <br />January 7, 2009 <br />3. Rule 4.05.16(2) requires that the discharge be a controlled and identifiable flow, meeting <br />the requirements of 4.05.2 for pH and total suspended solids. Initially the flow is controlled <br />and identifiable and the sample results initially submitted show that the discharge would <br />meet the effluent limitations for pH and total suspended solids. However, compliance with <br />4.05.2 and 4.05.16(4) requires that the discharge meet all applicable water quality standards <br />or effluent limitations. A discussion is provided on pages 2.05-72 and 2.05-73 regarding <br />potential impacts to the North Fork of the Gunnison River. There may be additional water <br />quality standards or effluent limitations that apply. With TR-54 (pending approval) the <br />effluent parameters associated with BRL's revised CDPS permit were expanded to include <br />additional parameters. These are given on the proposed PHC North Fork of the Gunnison <br />River table page 2.05-73i as submitted with TR-54. The Division believes that these <br />effluent parameters may then be applicable to the mine water discharge proposed with TR- <br />57. Please demonstrate compliance with 4.05.16(4) and ensure that all applicable effluent <br />limitations and water quality standards have been reviewed and that adequate baseline data <br />for the proposed mine water discharge has been collected and analyzed for the appropriate <br />constituents. <br />4. What is the expected water quality of the anticipated flow when it discharges to the river <br />and what impact would this have on in-stream water quality standards? In Item 4 on page <br />2.05-74 there is no mention of compliance with applicable water quality standards. Please <br />provide an expanded discussion of the estimated impact to water quality of the North Fork <br />of the Gunnison River. If appropriate, provide a revised PHC analysis to show that there <br />would not be exceedances of in-stream water quality standards as a result of the discharge <br />when combined 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-1 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 <br />from the proposed additional mine water discharge? In the last paragraph of page 2.05-72 <br />BRL states the following "The quality of ground water should not be impacted unless it <br />flows into the mine. The only potential impact the mine will have on ground water is to <br />intercept it in the underground workings." There is no discussion or update to the PHC to <br />describe the effects of the proposed mine water discharge on groundwater quality in the <br />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 <br />verifying the assumptions made regarding compliance with effluent limitations and water <br />quality standards. Please update the monitoring plan with a proposed schedule including <br />parameters and sample frequency for the discharge from the active B-Seam workings.