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., <br />TABLE OF CONTENTS <br />Page <br />I. BECAUSE BATTLE MOUNTAIN'S APPLICATION IS <br />INCOMPLETE, THE BOARD IS REQUIRED TO DENY IT ................1 <br />A. The Application Fails To Address Either The <br />Project Water Requirements Or The Water Rights <br />And Sources Of Water For The Project ...................1 <br />B. Additional Inadequacies Of Battle Mountain's <br />Application ............................................6 <br />1. An Adequate Slurry Wall Must Be Constructed <br />Along The South Wall Of The West Pit To <br />Prevent Dewatering of the Rito Seco ...............6 '~ <br />2. Battle Mountain Has Failed To Demonstrate That <br />There Will Be No Acid Generation ..................7~' <br />3. Battle Mountain Has Failed To Provide Mill <br />Facility Design Specifications ....................7 <br />4. Although Battle Mountain Has Agreed To A <br />0.2 ppm Level Of Free Cyanide In Waste <br />Materials, They Have Failed To Specify <br />The Point At Which Such Levels Will Be <br />Measured ..........................................8 <br />5. Battle Mountain Has Failed To Provide <br />Information Concerning The Lining Of <br />Ditches Carrying Cyanide Solution .................9 <br />6. Battle Mountain Has Failed To Obtain A <br />Timely Review And Comment From The Division <br />Of Wildlife .......................................9 <br />II. BATTLE MOUNTAIN'S RECLAMATION PLAN FAILS TO CONFORM <br />TO THE REQUIREMENTS OF THE ACT .............................10 <br />A. Battle Mountain Has Failed To Adequately Ensure <br />That The Toxicity Of The Heap Leach Pile Will Be <br />Neutralized During Reclamation ........................10 <br />H. Battle Mountain Has Failed To Demonstrate That <br />Erosion Control Measures Will Be Maintained <br />During Reclamation ....................................11 <br />i <br />