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iii iiiiiiiuiiu iii 999 STATE OF COLORADO • DIVISION OE MINERALS AND GEOLOGY Depanmenl o(Nalural Resources 1313 Sherman 51., Roam 215 Denver, Colorado 80203 Phone: (3031 866-3567 FA\: (3031 832-8106 Date: July ], 7999 To: File M-88-112 /,,j~~ From: Harry Posey ~j~iz" ti-'" r Subject: EPA water quality monitoring oblems; Battle Mountain Resources Inc., San Luis Project, M-88-112 Greg E. Watcher Esecmive Dvector n~¢hael B. Long Division Director l~~ During the week of June ~ri, ]999, a team from EPA collected surface water samples along the Rito Seco, adjacent to the above captioned (BMRI) project. The team collected three surface waters and a seep sample, and splits were taken by Ron Zumwalt for BMRI. (These are being analyzed currently, and results should be forthcoming.) In addition -and apparently unknown to BMRI - a second EPA crew collected a seep sample, which was characterized as a grab sample. • Analytical results from the grab sample were provided by Carol Russell, EPA, who directed the collection of the sample. The analysis was labeled "enforcement confidential." The grab sample was analyzed according to the "total recoverable" method. As can be determined from the results, the grab sample contains on the order of 11 grams of solid material per liter of solution. This is an unacceptably high amount of sediment for a water analysis because metallic elements, which are present in ordinary rock and soil minerals and organic compounds, appear in the analysis when analyzed by the "total recoverable" method. The results from such samples provide nil insight about water quality or potential metal toxicity to aquatic life. Aquatic life are presumed to be susceptible to dissolved metals, and water quality standards (except mercury) are established on that basis. However, because the analyses are overwhelmed by contributions from the sediments and organic matter, and because these sediments and organic matter cannot be presumed to be able to provide metals at the levels indicated by the analysis, the analysis is of no apparent use. Overall, such analytical results provide nothing but potentially misleading information. The "total recoverable' method of analysis measures metals dissolved in the water plus metals present in solid particles, if such particles are soluble in hot nitric acid. This method would report metals present in acid-soluble soils and rock forming minerals plus metals contained in organic matter. By this method, most of the major and minor rock forming minerals, except quartz, dissolve in the analytical solutions, and their contained metals report to the analysis. In addition, common secondary minerals such as iron and manganese oxides, which preferentially incorporate high concentrations of other metals, likewise report to the analysis. This provides very biased indications of what might be present in the water and bioavailable. DIVISION OF MINERALS GEOLOGY R E C L A M A T I O N MINING•SA FETY Bil I Owens Governor For the record, the analytical information for the grab sample is provided with this note. However, it is • recommended that no credence be given to this analysis. A check of the recent groundwater monitoring information submitted by BMRI indicates that EPA's seep grab sample is not at all characteristic of the