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12!10!98 THU 18:17 FAS • (31012 • CONCLUSION ~~ We appreciate the opportunity to submit these comments to the DMG ahtd MLRB. Based on the short notice that local citizens in San Luis have had to respond to the co pany's information, further analysis is warranted. In sum, we strongly urge the DMG ~nd MLRB to take the fol]owing actions: (L) Find that $MRI has violated its MLRB permit and order approp}iately sufficient fines and/or civil penalties (at least the statutory minimum) for each day such ~olations have occurred; (2) Establish ground water compliance levels that match existing co ditions (i.e., recognize that the most appropriate `arse" of ground water in the West Pit and b~tween the West Pit and the Rito Seco Creek is recharge of the Creek); (3) Expand the number and scope of permit Points of Compliance ( Cs) to include, at a minimum, the newly discovered seep discharging into the Rito Seco Creek. B 's ongoing collection and pumpback apparatus provides an easy sampling/monitoring point (4) Increase the amount and duration of the existing financial ass ce to account Y'or all ongoing and projected costs for ground water mitigation, pumping, monito ' ,and potential treatment and other reclamation. As a preliminary matter, the DMG/MLRB sho d demand a full cost accounting and estimate for all of these measures from BMRl; (5) The DMG should coordinate its efforts with the Water Quality C .ntrol Division due to the potential violations of the Clean Water Act and Colorado Water Qual~y Control Act from the unpenuitted discharges from the West Pit into the Rito Seco Creek. We look forward to discussing these issues in more detail in the coming days and weeks and look forward to the MLRB hearing scheduled for December I ti, 1998. Thank you, .[~ubc~ r~rxu v Attomey for the Peoples A tetnative Energy~Services Cc: Mark Held, Attorney General's Office Steve Brown, Attomey General's Office ]. David Holm, WQCD Maria Mondragon-Valdez, PAES Mined Land Reclamation Board Carol Russell, EPA Mine Waste Team