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<br /> <br />they do not fail any of the hazardous waste requirements of <br />either the State of Colorado or the federal Environmental <br />Protection Agency and to assure that there is not a large <br />accumulation of free cyanide in these materials. <br />F. Battle Mountain's Spill And Release Reporting Pr <br />om <br />Battle Mountain suggested in its response to F~oint <br />No. 43 a reporting and mitigation schedule for heap leach pad <br />leaks. Battle Mountain proposed to monitor the secondary leak <br />protection system on a weekly basis after the initial month of <br />operation. This is inadequate because it will allow Battle <br />Mountain to discharcLmore than 6,000 gallons of cyanide solution <br />to the environment without implementing responsive or corrective <br />actions. Any discharge to the environment requires National <br />Pollutant Discharge Elimination System permit from the Colorado <br />Department of Health and should be immediately remedied by Battle <br />Mountain. Battle Mountain also suggested that they can have a <br />release of up to 100 gallons per acre per day of cyanide solution <br />and merely pump the sump dry without taking any action to <br />identify the source of the leakage and to repair it. :..00 gallons <br />of cyanide solution being leaked over a period of a weeek would <br />allow Battle Mountain to discharge more than 30,000 ga:.lons of <br />cyanide solution without taking any action other than i:o pump the <br />-17- <br />