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12/10/'98 THU 18:14 FA3 • f~006 <br />' • <br />WESTERN MINING ACTION PROJECT <br />1405 Arapahoe Ave. <br />$oulder, CO 80302 <br />(303) 473-9618 <br />Fax (303)440-8052 <br />wmap(aigc.org <br />Via Fax - Hardcopy to Follow By Mail <br />December 10, 1998 <br />Colorado Mined Land Reclamation Board <br />C/o Mr. Michael Long, Director <br />Colorado Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Re: Battle Mountain Resources Inc., San Luis Project, M-88-112 <br />Dear Mike: <br />This letter is submitted on behalf of the Peoples Alteroative Energy Servic s (PAES), by <br />and through its undersigned attorney, and regards recent and ongoing concerns wi BMRI's San <br />Luis Project (Mine). PAES has been actively involved with issues at the Mine fo over ten yeah <br />end has participated in numerous DMG and MLRB hearings and discussions sinc 1988. <br />It has come to our attention that the DMG and MLRB are currently revie g various <br />options for dealing with the permit violations and other concerns stemming from a Mine's <br />exceedences of water quality protective levels. This letter details our concerns wi h BMRi's <br />proposed approach and DMG/MLRB response. We have reviewed recent water q ity and other <br />information as best as can be done on short notice and reserve the right to submit dditional <br />comments as the situation develops and more information comes to light. <br />Overall, it appeazs that a serious water quality problem may be developing at the site. At a <br />minimum, surface and ground water standards are being violated as a direct result of the Mine's <br />activities and its alterations of the hydrologic regime in the area. We respectfully equest that the <br />DMG and MLRB take specific actions to ensure that all statutory and regulatory r sponsibilities <br />are met and that BMRI is held fully, accountable for its acrions. Based on our revi w to date, our <br />specific concerns follow. <br />I. Surface and Ground Water Quality Is Not Being Protected <br />The data and analysis submitted by BMRi acknowledges that surface and ~ound water <br />standards are not being met at the site. Specifically, ground water protective level set in the <br />