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 7
Status: Satisfied - BMG has agreed to work with the Division bo develop
a critical path management schedule follo~ing the
initial resolution of all abatement issue in a
letter of April 16, 1992.
(12) Modification of Monitor Sampling & Analysis Protocol:
During the implementation of the tailings cyanide detoxificati n project,
approved under item (4), question arose regarding the accuracy of water
quality results generated by BMG in performing required sampli g. The
Division requested that BMG verify the accuracy of their water quality
monitoring analysis. In response, BMG completed comparative a~alyses of
split samples using two independent EPA certified laboratories and their
own San Luis facilities. The results of these analyses demons rated
significant discrepency between the three independent analyses.)
BMG, in order to ensure accurate monitoring of water quality, hall
complete a comprehensive evaluation of the procedures used for sample
collection, preservation, transportation, analysis and reporti g. At a
minimum, this evaluation shall include consideration of legal 'chain of
custody", prevention of contamination during sampling, prepara ion and
preservation of samples, appropriate transportation of samples to the
laboratory, "quality assurance/quality control" (QA/QC> method logy
within the laboratory, split sampling redundancy and verificati n of
monitoring accuracy. This evaluation, including a detailed sa piing and
analysis protocol, shall be submitted to the Division as a technical
revision no later than Monday, May 4, 1992.
Status: Satisfied - BMG completed the split sample analyses an submitted
the results to the Division on April 21, 1 92.
- The requirements for protocol development nd permit
revision were only advanced by the Divisio on
April 21, 1992.
- BMG has verbally committed to protocol modification
on April 22, 1992.
MLRB Amendment: The protocol shall include the sampling of thethree
lysimeter sets installed in response to Water Court requirements.
The protocol shall specify monthly reporting of results t the
Division. A third party or parties, approved by the Divi ion,
shall complete collection and analysis of water quality s mples, at
BMG's expense on a bi-weekly frequency. ~
Copies of the detailed sampling and analysis protocol sha 1 be
provided to interested local parties in San Luis. The Di ision
shall allow the interested local parties to submit commen s for the
Division's consideration until May 13th. ~