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e <br /> <br /> <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman 51., Room 215 <br />Denver, CO 80201 <br />Phone: (3031 866-3567 <br />FA%:(3031832-8106 <br />December 22, 1993 <br /> <br />o~ coto <br />tid <br />Ne <br />.. <br />~ 1816 <br />Roy Romer <br />Governor <br />Michael B Long <br />Divrsion Dnedar <br />Ms. Alana L. Scott <br />Environmental Engineer <br />Battle Mountain Resources, Inc, <br />P.O. Box 310 <br />San Luis, CO 81152-0310 <br />Re: San Luis Project (Permit No. M-88-112) Adequacy Review of <br />Proposed Technical Revision 15 <br />Dear Ms. Scott: <br />The Division has conducted a preliminary, not complete, adequacy <br />review of the above referenced technical revision and has the <br />following concerns: <br />PART 1: While basically inclined to favor the proposed method of <br />demonstrating water quality in the Sante Fe aquifer prior to <br />requesting release of reclamation responsibility and bond, the <br />Division is being asked to approve a concept when it is not <br />familiar enough with the drilling, completion, and sampling of <br />shallow, angled monitoring wells to accept such a proposal without <br />some demonstration of feasibility. <br />BMRI will have to provide additional information demonstrating the <br />practicality of the concept. Such questions as the identity, <br />location and availability of a drilling contractor providing such <br />a service will have to be answered, What are the specifics of the <br />drilling method and the limitations, ie. can a usuable well be <br />drilled to reach a target approximately 200 feet lower that the <br />drill site location in a lateral distance of an estimaited 500 to <br />600 feet? For bonding purposes, what is the estimated cost of <br />drilling, completing, testing, and sampling? How will the sampling <br />of the aquifer in such a well be carried out? Where have <br />monitoring wells with comparable characteristics and requirements <br />been drilled and successfully employed and for how long? If <br />similar, how do any such monitoring wells differ frotrn what is <br />proposed here? <br />PART 2: The adequacy review of this section of the proposed <br />technical revision will be delayed to a large degree until the <br />adequacy concerns for PART 1 are satisfied, but the Division will <br />proceed to evaluate, and advise you on the adequacy of, those <br />aspects of proposed monitoring, points of compliance, permit <br />