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i • Page 5 i December 14, 1998 BMRI's own data, as summarized in Table 2 indicates that, lacking a significant decrease in Sulfate levels in M-11 R, by the December 1601 hearing date an ongoing violation of at least 75 days has occurred. 2) Additional Wells According to the November "TR-15 Response Plan", following a September 28" meeting between BMRI, its consultants and the DMG, BMRI began to collect additional water quality samples from groundwater wells "not previously designated for on-going monitoring."12 Test results from wells in the backfll and the pit wall were taken between October 1r and 5" registering TDS and Sulfate levels in violation of permit standards. BF-2 had a Sulfate concentration of 1369.5 mg/L and a TDS level of 2293 mglL. PW-1 had a Sulfate level of 1257.5 mg1L and a TDS concentration of 2105 mg/L. An additional well in the backfill (BF-1) was found to have a Sulfate level of 245.5 mg/L and a TDS concentration of 546 mglL, troth within permit standards, but certainly elevated. BF-2 is a 57 ft. deep well into the west pit backfill. The purpose is a baseline wbll. PW-1 is a 47 ft. deep well. It penetrates into the Rito Seco Alluvium; its purpose is to monitor pit Stability. BF-1 like BF-2 is a baseline well in the west pit backfill, its depth is 82 ft. 3) Summary There appears to be a trend in ground water samples within the ball of trie pit and at localized sites in the Rito Seto Alluvium downgradient from the west pit. Elevated levelk of TDS and Sulfates have been identified consistently since July of 1998. These trends have not yet been detected in the few deep wells in the vicinity of the west pit. The duration of permit violations detected in compliance ground water monitoring wells are concurrent. The longest active TDS violation will be 161 days old on the hearing date while the ongoing Sulfate violation will be 75 days olp. Additional violations in wells not designated as compliance wells will have been collected 66 days e~riier. It is no Longer "pre-mature" for the MLRB to issue BMRI with a violation. Compliance with releNant statutes, regulations and permit conditions has clearly been neglected, the time is ripe to issue. a~ violation and appropriate fines . B) Surface Water The November "TR-15 Response Plan" incorrectly states that, "at no time have the in-stream values exceeded stream standards for the Rito Seto."'a As our summary describes, singe as early as 1994 Manganese concentrations in the Rito Seco have not complied with state water quality standards. Furthermore, TDS and Sulfates levels in the Rito Seco have become drastically elevat d in the past year. TDS and Sulfate have been rising in concentration since as early as October of 197, although not yet violating in-stream standards. BMRI's monitoring efforts have provided ample evidence that water quality conditions in the Rito Seco have been altered within the localized area~of the Mine, reflecting changing Vends in TDS and Sulfates that do not exist at BMRI's upsVeam monitbring station. The November TR-15 Response Plan also reports that surface discharge on they banks of the Rito Seco has occurred. Groundwater from the west pit has surfaced and communicated with the Rito Seco. Water samples taken from this discharge indicate that it was above permit conditions for at least three separate parameters. 1) Rito Seco Creek ~- BMRI, November 1998, TR-I S Response Plan, Page 2. "BMRI, November 1998, TR-15 Response Plan, page I5.