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5EM11T BY: XEROX Telecopier 701 1-27-94 3~49PM ~ 3034406052y <br />' ~OLQBADO MINING ACTION PROJBCT <br />1405 Arapahoe Ave. <br />Boulder, CO 80302 <br />(303) 440.4901 <br />Fax (303) 440-8052 <br />V1a Fax <br />January 27, 1994 <br />Mr. James C. Stevens <br />• Sr. 8mlronmental Protection Specialist <br />Colorado D1vlsion o! Minerals and Geology <br />1313 Sharman St., Room 215 <br />Darner, CO 80203 <br />Re: Battle Mtn. Oold (BMG) San Luis PrQjeet (K-88-112): <br />Ob~eetora Coaments on your Jan. 7, 1994, latter to blSG <br /> <br />Dear Jim: <br />303 832 6106 # 2 <br />On behalf of the Party Ob~actora in the ongoing efforts to bring BMO <br />into compliance with their Mined Lastd permit, xs would like to offs} these <br />brief eommsnte on your Jan. 7, 1994 latter to Alana Scott (BMC). O~srall, ve <br />support the efforts of the Division to require additional inlormati n from BMG <br />regarding ground vntss quality. Specifically, va support your raqu~at for <br />additional points of compliance and immediate reporting to ensure tt~e quickest <br />possible enforoomant and corrective actions if say contaminants era released <br />into ground water. <br />In addition, as a member of the negotiating team along with Bruce <br />Humphries, Maxima Stexart, and repreaentativea from the Colorado mining <br />industry in the two-year rulemaking procses to develop the Division's ground <br />xater regulations (1991-1993), I would 11ke to comment on the ground vales <br />protections that are applicable to BMG'a operation. As you correctly point <br />out, the currant correct numerical protection levels for ground vat~r are <br />domestic, not agriculture u SMG would like. Under Rula 6.2.(3), BNG moat <br />protect all "reasonably potential future uses of ground water" thatimight be <br />impacted by a ralsaee. Clearly, and as xe era psepared to show if necessary, <br />domestic use of ground water ~lther currently exists do.mgradient from the <br />^ite or in any event, is highly likely in the Haar future. <br />Horever, this system of Division regulation will undergo a substantial <br />change on thi^ coming Monday, Jan. 31, 1994. On that data, the recently <br />revised Interim Narrative Standards (INS) for Ground Water of the W tar <br />Qualiey Control Commission become effective. Under Chia revision (~dopted by <br />the Commission in December, 1993), the INS mill apply to the entire state, not <br />duet the limited aquifera.(San Luia Valley among them) that were previously <br />classified by the Commission in 1991. Thus, BMC's argument concerniing the <br />geographic scope of the old INS will become a moot point on Monday. <br />Vndsr the INS (5 CCR 1002-8, 3.12.5), all diechargea to ground water <br />under the authority of the implementing agsneie^ (i.e. Mined Iind) duet meat, <br />for each pnrametss, either the sxieting ambient quality as of Jan. 31, 1994 p= <br />the domestic quality table values contained in the Commleslon'a Ground Water <br />