ENFORCE30845

• Permit No: M1988112
• IBM Index Class Name: Enforcement
• Doc Date: 4/27/1992
• From: MINERAL POLICY CENTER
• To: MLRD
• Media Type: D
• Archive: No

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24 April 1992
Dr. Jim Pendleton
Director, Technical Services
Mined Land Reclamation Division
Colorado Dept. of Natural Resources
1313 Sherman Street, 2nd Floor
Denver, Colorado 80203
FAX: [phone]
Dear Jim:
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I'd like to offer some suggestions which I h~pe
will be helpful for follow-up action on the Battle
Mountain Gold mine and mill at San Luis.
Mineral Policy Center testified on behalf of; the
Costilla County Committee for Environmental Sound ess
at the MLRB hearing on this facility on 25 Januar
1990. At that time we alerted the Board that the a was
objective reason to be concerned that the deposit d
tailings might contain higher levels of cyanide t an
was predicted by BMG. Unfortunately, our predictions
were accurate.
There may now be a large amount of free or w akly-
complexed cyanide entrained in the deposited tailings
at the site, within a liner which is not adequate for
the risk. As you may recall, the MLRD specificatson
for permeability in the soil substrate was lowere at
BMG's request, beneath the Division's initial req ire-
ment in the permit review process. The surface p nd
toxicity is one problem, but the entrained cyanid is
more intractable.
I would suggest that the first step be to ob ain
samples of the mass of tailings at various depths, and
to analyze those for WAD cyanide and for total le ch-
able metals. All previous assumptions about the Fompo-
sition of the tailings should be re-tested.
If the tailings prove hazardous for either m tals
or cyanide, full correction should be required be ore
the mill is permitted to resume operation.