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~~~~yE~, <br />~ + SEP 0 81992 <br />DIVISIUIV OF <br />RESPONSES TO THE COLORADO MINED LAND MINERALS 8 GEpLUG~ <br />RECLAMATION DIVISION'S COMMENTS <br />ON BATTLE MOUNTAIN RESOURCES' ADEQUACY RESPONSES <br />TO TECHNICAL REVISION NO. 6 1`'~i 7 <br />G `~ t <br />< < r, l r <br />S~F ~ kt.L~ <br />~.,_.~- <br />C tC <br />RESPONSE TO COMMENTS BY HARRY POSEY <br />I. BMRI and its consultants have surmised, without supposing data, that the ground <br />water gradient directly beneath the tailings impoundments is werterly, on trend <br />with the surface topography. Though reasonable, this is noA proven. The <br />Division is concerned about the fate of any release from the ¢ailings ponds. <br />Whether a release would flow iruo the Rito Seco, the Culeubra [siQJ, or to ground <br />water unrelated to these drainages is not known. <br />BMRI needs to idemify the likely fate of a potential release from tke tailings pond <br />and establish routine sampling in that area. <br />eh <br />`' 1( <br />RESPONSE: The identification of the pathway that any potential release would take from the <br />tailings pond is addressed in the second phase submittal associated with Technical <br />Revision No. 8 (the additional wells have established the local ground water <br />gradient and site-specific aquifer hydraulic characteristics) and Technical Revision <br />No. 9 (which provides for containment of both surface and gro(~nd waters that <br />would be contaminated if a release occurred). BMR proposes that monitoring <br />wells installed as part of Technical Revision No. 8 be included ins the monitoring <br />described in Technical Revision No. 6; therefore, we believe that the Division's <br />concern identified in this comment has already been addressed. <br />2. The Division expects that once the hydrologic gradient in the vicinity of the <br />tailings ponds is established, an appropriate number and apprt{priate types of <br />sampling stations will be established. <br />RESPONSE: BMR agrees with this concept, as evidenced by information provided in the <br />second phase submittal for Technical Revision No. 8. <br />3. 77te Division expects that sample containers, reagents, and wash solutions will be <br />supplied by the third parry samplers. 77te Division further expec[~ that access to <br />monitoring wells will be strictly controlled by BMRI. <br />RESPONSE: The Memorandum of Understanding between the Colorado Division of Minerals <br />and Geology and BMR concerning third party verification satttpling and the <br />