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' '! ~ ~ III IIIIIIIIIIIIIIII <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmenl of Natural Resources <br />I }13 Sherman 51., Ruom ?15 Ily~~ <br />Denver Colorado 80203 I <br />Phone: 1}031 866-3567 <br />FAY: 13031 R32-R I U6 <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />December 18, 1995 <br />Roy Romer <br />Governor <br />Ms. Anne C. Baldridge IamesS Lochhead <br />Director of Environmental and Governmental Affairs Exec o~rve oireanr <br />Battle Mountain Gold Company Michael R. lung <br />5670 Greenwood Plaza Blvd., Ste. 106 Division Director <br />Englewood, CO 80111 <br />RE: San Luis Project (Permit M-88-112) Technical Revision 15, Part <br />2 Adequacy Response in behalf of Battle Mountain Resources, Inc, <br />(BMRI) dated December 1, 1995. <br />Dear Ms, Baldridge: <br />This letter is intended to provide BMRI a written review by the <br />Division of BMRI's above referenced Part 2 response including a <br />record of the Division's comments made during our meeting with you <br />on December 8, 1995. All aspects of the BMRI Part 2 response were <br />not discussed in the December 8, 1995 meeting; much time was spent <br />on Part 1 issues. As a result, this letter will serve to identify <br />both those areas of Part 2 where agreement appears to have been <br />reached between BMRI and the Division as well as those of possible <br />disagreement which remain to be addressed. <br />BMRI should understand that it is the Division's intention with the <br />approval of TR 15 not only to establish a site wide ground water <br />monitoring plan to be followed for the San Luis site but also to <br />set Permit Conditions and Points of Compliance for groundwater at <br />the site as required by Rule 3.1.7. BMRI did reference a portion <br />of the older 6.2.(3) groundwater rule, which was equivalent to Rule <br />3.1.7, when BMRI made their voluntary submittal of ground water <br />information in December 1993 as Part 2 of TR 15. In BMRI's most <br />recent adequacy response, however, BMRI made no mentioh of Permit <br />Conditions and Points of Compliance and referred only to such <br />things as "indicator parameters", "upper control limits", etc, <br />Hopefully, the absence of any reference to Permit Conditions and <br />Points of Compliance in the BMRI response does not mean BMRI has <br />misunderstood the Division's intention for TR 15. <br />PART 2 RESPONSE INTRODUCTION <br />Resolution of the TR 15 <br />Division but BMRI was <br />January 7, 1994 lett <br />statistical approach to <br />never done. <br />Part 1 concerns was important to the <br />invited as early as the Division's <br />er to demonstrate their proposed <br />setting Permit Conditions. This was <br />