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• III IIIillliililllli <br />\I\AYI~a Wu~ <br />~\A~ PO Bo u42 Place <br /> San Luis, CO 81152 <br />~/ <br />D~~ <br />"~J Fx' 719 6720140 <br />December 14, 1998 <br />~ ,~. sc~~ <br />_i~.- "*- <br />_jiC~ <br />Mr. Michael Long, Director „ _ <br />Colorado Division of Minerals and Geology - ; <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 -'' ~'nFr" ~ ~ G?c:c~; <br />Re: Battle Mountain Resources Inc., San Luis Project, M-88-112 <br />Dear Sir: <br />This letter is submitted on behalf of the Costilla County Conservancy District (CCCD) regarding <br />our ongoing wncems with the Battle Mountain Resources Inc. (BMRI) gold mine (Mine) outside of San <br />Luis, CO. We have been actively involved with issues associated with the Mine since it was proposed <br />in 1988. We are historic objectors to the mine because of concerns related to changes in water quality <br />and the effects of such changes on downstream uses. The purposes of the OCCD are the <br />conservation and development of water for agricultural, municipal and industrial used regulation of <br />stream courses, and flood prevention. <br />We are aware that the December 16" Mined Land Reclamation Board (MLRB) hearing will <br />consider BMRI's recent permit violations. We are also aware that since September, two response <br />plans have been prepared on behalf of BMRI to address recent changes in water quality, and hydraulic <br />interactions between the Mines west pit and the Rito Seco Creek. This letter details both our concerns <br />with conditions at the Mine site and the Division of Minerals and Geologys (DMGJI and MLRB's <br />responses to these problems. We have reviewed the materials prepared by, or for, BMRI and <br />additional water quality and hydrological information as was feasible considering the short amount of <br />time which we were afforded to respond. Additional expert opinions provided to the CC¢D conceminq~ <br />these matters will be presented by Scott Medford of Hydrokinetics Inc. during the December 16 <br />hearing. Mr. Medford is expected to request the installation of at least three additional mgnitoring wells. <br />We reserve the right to submit additional analysis and comments as more information becomes <br />available or as the situation changes. <br />The recent developments surrounding the west pit indicate that severe water quality <br />problems may be developing. Ground water standards, for at least one parameter (total dissolved <br />solids - TDS), at M-11R have been actively violated since July 8, 1998. By the heating date, this <br />violation will constitute an ongoing violation of at least 161 days. Furthermore, standards for Sulfate <br />levels within this well have been violated since October 2ntl; by the permit hearing date, this violation will <br />represent an ongoing violation of at least 75 days. Surface water quality standard violations have also <br />occurred within the Rito Seco over the past year. The post mining Manganese levels et RS-2 have <br />averaged well above state water quality standards. Finally, on October 28'", BMRI reported an active <br />discharge into the Rito Seco Creek, a "water of the United States". The duration and cegsation of this <br />discharge are not established as fact. Water samples from the discharge indicate that it was beyond <br />permit conditions and state water quality standards. The best information available indicates that these <br />violations are a direct result of the Mine's actions and alterations of the hydraulic regime of the west pit. <br />We respectfully request that the DMG and MLRB take actions to ensure compliance of BMRI <br />with all statutory and regulatory requirements and hold BMRI completely accountable for its actions. <br />CCCD Page 1 12114!98 <br />