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PEOPLES ALTERNATIVE ENERGY SERVICES RT. 1 BOX 3-A SAN LUIS, COLORADO @1152 July 28, 1993 Division of Minerals and Geology Department of Natural Resources 1313 Sherman Street Room 215 Denver, Colorado 80203 Attn: Larry D. Oehler Dear Mr. Oehler, gECEl~ -!_ A~1G 91993 Dn~i~icn ci r:~~ne~~s 5 ~..-u.:yr Peoples Alternative Energy Services (P.A.E.S) has completed (review of the Modification of Tailings Reclamation Plan and Amendment of Financial c~Rty abatement report for Battle Mountain Gold (Permit M-88-112)1, In studying the two volumes of information and accompanying data we h~ve the following concerns and comments: 1) EPA Method 1312 uses a considerably weaker acid when compared) to the prescribed extraction reagents used when pertorming the TCLP pros ures which we feel would have been more appropriate for the leachate test . 2) The relationship between samples run for leachate testing and the data presented are so nebulous that we cannot decipher what data goes wi~h what site/depth for this particular set of information. 3) In general, there appears to be considerable sample selection forth testing leading to uncertainty in our minds regarding vertical sites selected. can not be sure that leachate tests were performed at the proper vertical level ('.e., at the level where tailings were deposited during the time when excessiv ly high levels of cyanide were being put into the ponds). 4) The detection limits for selenium analyses are not low enough for ot~taining significant data. 5) It would have been a good idea to perform leachate tests on the sarr~e sample (site 8.5) that pore water analysis were conducted to determin how much of the metals, etc.. were tied up in the solid phase at that particular location.