ENFORCE31647

• Permit No: M1988112
• IBM Index Class Name: Enforcement
• Doc Date: 5/27/1992
• Doc Name: NOV & ORDER
• Media Type: D
• Archive: No

Battle Mountain Gold
NDPV Abatement Requirements
page 6
The description of each discrete abatement task element should include:
(a) Methodology and practices to be applied,
(b) Risk entailed,
(Is it proven technology, methodoiogy perfection, research, etc?)
(Is it subject to seasonality, weather, equipment avail bility?)
<c) Criticality of the task element,
(Consequences of failure or delay for abatement progresk)
(d) Decision points,
(e) Necessary relationship to other plan elements,
(Must it occur before or after other specific task elements?>
(f) Alternative methodology or practices, ~
(TO be substituted if failure or delay encountered)
(g) Required elapsed time,
(h) Name of the responsible staff member(s) or contractor(sb,
(i) Resources to be committed,
(BMG staff, consultants, equipment, lab),
(j) Required agency response(s), and
(Review and approval, site visit, meeting, permit issua~ce, etc>
(k) Abatement plan deadlines.
Status: Satisfied - 8MG has agreed to work with the Divisionlto develop
a critical path management schedule foll~wing the
initial resolution of all abatement issu s, in a
letter of April 16, 1992. ~
(12> Modification of Monitor Sampling & Anaiysis Protocol:
During the implementation of the tailings cyanide detoxification project,
approved under item (4), question arose regarding the accurac of water
quality results generated by BMG in performing required sampling. The
Division requested that BMG verify the accuracy of their Ovate quality
monitoring analysis. In response, BMG completed comparative nalyses of
split samples using two independent EPA certified laboratories and their
own San Luis facilities. The results of these analyses demonstrated
significant discrepency between the three independent analyses.
BMG, in order to ensure accurate monitoring of water quality, Is hall
complete a comprehensive evaluation of the procedures used for sample
collection, preservation, transportation, analysis and reporti g. At a
minimum, this evaluation shall include consideration of legal 'chain of
custody", prevention of contamination during sampling, prepara ion and
preservation of samples, appropriate transportation of samples to the
laboratory, "quaiity assurance/quality control" (QA/QC) method logy
within the laboratory, split sampling redundancy and verificat on of
monitoring accuracy. This evaluation, including a detailed sa piing and