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<br />6) There are a number of statements where "the lab was in error" or "data was <br />aberrant" (e.g., pages 22, 29). In the past we have observed this type df <br />dismissal of data when ever lab figures did not correlate with expected results. <br />7) On page 32 the statement is made that rinsed sam for <br />leachate testing however, in Table 3.8 the report cites data for ri pper <br />impoundment operational tailings. <br />8) Does acid pH used in leachate test cause cyanide to go into gaseous form <br />and, if so, is this gas captured and measured as part of the testing procedure? <br />9) Pages 34-35: Was only one sample measured for pore water? <br />10) Is BMG planning to use the tailings pond as a part of a future landfi~l site? <br />P.A.E.S. is deeply concerned that the Battle Mountain tailings site <br />contains unique chemical features which were not planned for in the initial <br />permit application. Because high concentrations of cyanide were so stratified <br />we feel that there is uncertainty of the actual chemical profile of the p~nd and <br />uniform detoxification of its contents. <br />We are further concerned that the deterioration of the single plastic liner <br />will be hasten as a result of the by-products of several detoxification <br />compounds. We are aware that BMG's plastic liner was partly installed in <br />winter conditions on rugged, often steep, rocky terrain, with malfunctiohing <br />wedge welders. In reviewing a series of evaluative letters from Allen Sorenson <br />(April to June 1992) regarding primary and secondary composite liner) <br />,especially the June 24 letter. We feel that there is a distinct possibilityof liner <br />failure, in the future, because leakage calculations were underestimatdd, <br />permeability assumptions were approximated, and quality control of only 0.1 <br />square cm./acre of liner is unproven. After the Summitville mishap with] liner <br />instillation we feel that we must proceed with caution especially when a large <br />volume of unknown chemical compounds and toxic tailings are loca~ed above <br />our community aquifer. <br />