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<br />Mr. Andre J. Douchane -3- April 9, 1993 <br />Battle Mountain Gold Company <br />tailings facility prior to any request by BMR for full release of <br />reclamation responsibility and bond. <br />In addition to the above, there remains the issue of the acceptability of the three monitoring <br />wells that currently compose the monitoring network. Comparison of field parameters for <br />water samples taken from wells M-9 and M-12, which were completed in the Santa Fe <br />Aquifer, appear, in terms of pH and EC, to resemble baseline samples of water recovered <br />from the Santa Fe and reported in the permit application. Water samples more recently <br />taken from these wells continue to show this similarity. This is not necessarily true of <br />water samples taken from well M-13. When M-13 was initially completed, the water <br />recovered from it exhibited significantly higher pH and lower EC values than are <br />encompassed by the range of such values for other water samples apparently from the <br />Santa Fe Aquifer. This characteristic has persisted. Most recently, it was reported by the <br />third-party sampler that, even when three well volumes of water were extractetl from M-13 <br />as a part of this procedure, EC values for the water samples had not stabilized. Although <br />the monitoring wells were completed over nine months ago, this well apparently still cannot <br />provide uncontaminated samples of water from the Santa Fe Aquifer. As a result, the <br />Division proposes the followiny condition to approval of TR-G8: <br />4) BMR will, within 60 days of the approval of TR-08, install a <br />replacement well for M-13 at a location acceptable to the <br />Division. The replacement well will be drilled, logged, and <br />completed in a manner acceptable to the Division and <br />comparable to that employed for wells PA-3 and PA-? 2. Evidence <br />demonstrating this installation will be provided to the Division <br />within 30 days of the completion of the well, This well will be <br />maintained and employed for ground water monitoring of the <br />Santa Fe Aquifer as is approved in the permit for wells M-9, <br />M-12 and M-13. <br />The Division considers the maintenance and continued use of the ground water monitoring <br />network for the approved period of time, the determination of ground water quality below <br />the tailings facilities and remediation of any significant contamination of ground water <br />detected by the monitoring or other means to be essential ingredients of the reclamation <br />plan. Completion of these should be guaranteed by the reclamation bond; how@ver, the <br />costs are difficult to estimate. The Division lacks direct experience in maintaining the <br />monitoring network; the means by which ground water quality below the tailings facility will <br />be demonstrated has yet to be determined; and the nature and duration of any rlemediation <br />efforts are quite uncertain. As a result, the Division proposes the following condition to <br />approval of TR-08: <br />51 Twenty percent of the total amount of financial warranty <br />required for reclamation of the worst-case disturbance at the <br />San Luis operation shall be retained by the Board and not <br />subject to release until ground water monitoring has been <br />completed according to the approved plan and far the approved <br />