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12x10!98 'tltII 18:11 F.~.S • • 0101? <br />CONCLUSION <br />We appreciate the opportunity to submit these comments to the DMG land MI RB. Based <br />on the short notice that local citizens in San Luis have had to respond ro the company's <br />information, further analysis is warranted. In sum, we strongly urge the DM(3 and MLRB to take <br />the following actions: ~~ <br />(L) Find that BMRI has violated its MLRB permit and order appropriately sufficient ~`'~ <br />fines andlor civil penalties (at least the statutory minimum) for each day such violations have <br />occurred; <br />(2) Establish ground water compliance levels that match existing conditions (i.e., ~" <br />recognize that the most appropriate `use" of ground water in the West Pit and between the West <br />Pit and the Rito Seco Creek is rechazge of the Creek}; <br />(3) Expand the number and scope of permit Points of Compliance ( OCs) to include, at,~p~~P~ <br />a minimum, the newly discovered seep discharging into the Rito Seco Creek. MRI's ongoing y4~~5'0~ <br />collection and pumpback apparatus provides an easy sampling/monitoring po' '(A <br />(4) Increase the amount and duration of the existing financial ass ce to account fo <br />all ongoing and projected cosu for ground water mitigation, pumping, monito ' g, and potential <br />treatment and other reclamation. As a preliminary matter, the DMG/1vII,RB sh uld demand a full <br />cost accounting and estimate for all of these measures from BMRI; <br />(5) The DMG should coordinate its efforts with the Water Quality Control Division <br />due to the potential violations of the Clean Water Act and Colorado Water Quaility Control Act <br />from the unpermitted discharges from the West Pit into the Rito Seco Creek. <br />r~~~ <br />~~,~. <br />~~ <br />u~~ <br />We look forward to discussing these issues in more detail in the coming days anki weeks and look <br />forwazd to the MLRB hearing scheduled for December 16, 1998. Thank you. <br />Attomey for the Peoples <br />Cc: Mark Held, Attomey General's Office <br />Steve Brown, Attomey General's Office <br />J. David Holm, WQCD <br />Maria Mondragon-Valdez, PASS <br />Mined Land Reclamation Board <br />Carol Russell, EPA Mine Waste Team <br />Energ}r Services <br />