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~ iii ~iiiiiiiiiiii iii ~ <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman $i., Room ? I S <br />Denver, Colorado 80203 <br />Phone: 13031 866-3567 <br />FAX:1303)832-8106 <br />February 7, 1996 <br />Ms. Anne C. Baldridge <br />Director of Environmental and Governmental Affairs <br />Battle Mountain Gold Company <br />5670 Greenwood Plaza Blvd., Ste. 106 <br />Englewood. CO 80111 <br />~-`~ <br />~~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames 5. Lxhhead <br />E.ecutive Duecwr <br />m¢hael B Lang <br />Division Dueclor <br />RE: San Luis Project (Permit M-88-112) Technical Revision 15, <br />Proposed Final Draft dated February 5, 1996 <br />Dear Ms. Baldridge: <br />The Division has received and reviewed the proposed final draft of <br />TR-15, referenced above. The Division has no major objections to <br />the submittal; although some suggestions as to content amd wording <br />will be made in this response in an attempt to ensure 1 complete <br />understanding between BMRI and the Division in regard to this very <br />important revision to the San Luis Project permit. The Division's <br />comments are as follows: <br />PART 1: MONITORING OF GROUND WATER BENEATH THE TAILINGS <br />FACILITY <br />No problem providing the Division correctly understands <br />the monitoring commitment. The Division's understanding <br />of the BMRI commitment is that groundwater monitoring <br />according to the approved plan will actually beycontinued <br />at the San Luis site for a least 9 years following the <br />cessation of tailings deposition or through the year <br />2006, whichever is longer. Since some reclamation of the <br />San Luis site has already taken place, it appears <br />confusing to the Division to include a separate reference <br />to an additional(?) one year period of monitori>rtg for the <br />implementation of initial reclamation unless it is made <br />very clear what this reference to "initial reclamation" <br />means and when it begins. Please confirm if this <br />understanding is correct. <br />PART 2: GROUND WATER MONITORING AND COMPLIANCE PROGRAM <br />GROUND WATER MONITORING POINTS: It might be best to alter <br />the references to wells 87-24 and M-10 as monitoring the <br />Santa Fe Conglomerate when they do not. Figure 1 <br />correctly indicates that 87-24 is a pre-Cambrian well and <br />