ENFORCE28992

• Permit No: M1988112
• IBM Index Class Name: Enforcement
• Doc Date: 5/23/1992
• Doc Name: BATTLE MOUNTAIN GOLD NOTICE OF PROBABLE VIOLATION ABATEMENT REQUIRMENTS
• Media Type: D
• Archive: No

Battle Mountain Gold
NOPV Abatement Requirements
page 6
(10) Adjustment of Financial Assurance:
As required by statute and regulation, any permit amendment or revision
approval will entail reevaluation of the cost of the entailed eclamation
components. BMG will be required to appropriately adjust its urety to
reflect any change in reclamation cost. Any permit amendment r
technical revision application submitted by BMG shall include n
appropriate evaluation of the implications of the requested pl n
modifications for the reclamation cost.
Status: Satisfied - BMG has agreed to comply in letter of Apr~l 16, 1992.
(11) "Critical Path" Project Management Schedule:
Common methodology and practices may serve more than one abate ent plan
task. Multiple tasks may occur simultaneously and may impose ignificant
simultaneous performance burdens on BMG and the Division. In rder to
recognize potential mutual benefits and to avoid conflicts and delay, BMG
should develop, maintain and implement one comprehensive, inte rated
"critical path" project management schedule for the abatement lan tasks.
The project management schedule for the BMG abatement plan tas s may be
complicated. Schedule maintenance could be facilitated by the use of
project management computer software (ie. ON TARGET, Harvard P oject
Management, TIME LINE, etc), which could be obtained by BMG an the
Division. This would accommodate efficient electronic exchang of
progress information. The schedule should be formatted as a detailed
"critical path" project management schedule. The schedule should be
divided into discrete task elements.
The description of each discrete abatement task element should ,include:
(a) Methodology and practices to be applied,
(b) Risk entailed,
(Is it proven technology, methodology perfection, researc etc?>
(Is it subject to seasonality, weather, equipment availability?>
(c) Criticality of the task element,
(Consequences of failure or delay for abatement progress)
(d) Decision points,
(e) Necessary relationship to other plan elements, I
(Must it occur before or after other specific task elementts?)
(f) Alternative methodology or practices, II
(To be substituted if failure or delay encountered) I
(g> Required elapsed time, I
(h) Name of the responsible staff member(s) or contractor(s),i
(i) Resources to be committed,
(BMG staff, consultants, equipment, lab),
(j) Required agency response(s), and
(Review and approval, site visit, meeting, permit issuance, etc)
(k> Abatement plan deadlines.