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ENFORCE27518
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ENFORCE27518
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Last modified
8/24/2016 7:35:07 PM
Creation date
11/21/2007 11:38:16 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1988112
IBM Index Class Name
Enforcement
Doc Date
5/23/1992
Doc Name
MEMO BMRI COMPLIANCE WITH MLRB ABATEMENT REQUIREMENTS OF 4/23/1992
From
COSTILLA CNTY CONSERVANCY DISTRICT
To
MLRB
Media Type
D
Archive
No
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<br />~~) <br />9) Amendment of tailings Area heclamation Plan <br />a) Independent Monitoring must be included here. <br />h) Why wait until after detox for this plan? <br />c) How do we know metals content of tailings does not represent a <br />threat? <br />d) Tailings testing must ,.~clude testing for cyanide and heavy <br />metals. <br />10) Amendment of Financial Assurance <br />, a) Any modification of the reclamation bond must be done through <br />an amended permit process allowing for public input. <br />11) Critical Path Management Schedule <br />a) given the amount of monitoring, the critical path management <br />schedule should be developed to help in a methodical approach to <br />complying with the abatement requirements. The commitment from BMG <br />here is as nebulous as the remedial plan called for inknumber 6. <br />12) Amendment of Monitor Sampling and Analysis Protocpl <br />a) Our expert, Dave Hyatt submitted to MLAD written pomments to <br />this proposal on May 7, 1992. What happened to them? <br />TASKS FOR INDEPF.NDF.NT MONITORING <br />1. Independent evaluation of BMC's initial hydrologic studies of <br />the area. (both as to surface and ground eaters. <br />2. Assessment of ground water wells and lysimeters as to need for <br />additional wells and/or lysimeters; need for increased monitoring <br />and to include increased monitoring of Well 111 (W-2236 w~ich is the <br />basis for the town's eater supply. <br />3. Review the Remedial Response plan proposed by BMC/ <br />4. Conduct testing of tailings as to cyanide and heavy( metals. <br />5. Assessment of the liner system and leak detection system in the <br />collection pond. <br />Lastly, ue feel that BMG should do any extensive testing in a <br />
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