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<br />BATTLE MOUNTAIN RESOURCES, SAN LUIS PROJECT <br />CMLRD ADEQUACY LETTER RESPONSES <br />Page 7 of 28 <br />Initial deposition will result in tailings solutions being directly <br />in contact with the drain layer. However, the potential increase in <br />head during the short period prior to tails covering the drain will <br />be over significantly less area. Total seepage rates during the first <br />year of operation are calculated to be less than these for the case <br />' considered above. <br />The extremely low level of seepage predicted by the calculations <br />' above, cannot migrate beyond the subsoil immediately beneath the <br />facility and, therefore, cannot affect hydrologic resources. <br />The monitoring wells were installed immediately downgradient of the <br />' tailings facilities and included screen sections in strata intervals <br />most likely to intercept groundwater flow coming from beneath the <br />tailings facility. If seepage flow from the tailings facility were <br />' to occur it would likely take place along the interface between the <br />Santa Fe Formation and the overlying alluvial material:c, along any <br />extremely porous zones acting as a conduit, and within the <br />groundwater table. The monitor wells were screened at these intervals <br />and will detect any leaks which create flow sufficient to cause <br />migration of fluids. <br /> 12. Please discuss whether the completion of angled drill holes within <br /> a the coiluvium beneath the tailings facility would provide beneficial <br /> information regarding leakage through the liner system. Another <br /> approach to Leak detection may be to place slotted ADS piping within <br />' the compacted colluvial material with an end open to the edge of the <br /> tailings facility. In any case, a provision to assess and mitigate <br /> leakage should be addressed. <br />' RESPONSE Th <br />t <br />ili <br />f <br />ilit <br />b <br />i <br />d <br />ith <br />i <br />h <br />d <br />t <br />t <br />t <br /> : e <br />a <br />ngs <br />ac <br />y <br />as <br />een <br />es <br />gne <br />w <br />a con <br />a <br />nmen <br />sys <br />em <br /> which includes the low permeability characteristics of the tailings <br /> themselves, a drainage layer to promote consolidation of the tailings <br /> and reduce the hydraulic head on the synthetic membrane liner and <br /> compacted subsoil. As discussed in Response 11 above, the potential <br /> leakage from the facility is predicted to increase the moisture <br /> content of the subsoils slightly, however, saturation is not expected <br /> to occur. Angled drill holes or ADS pipe located in the subsoil are <br /> unlikely to detect leakage of solution in the unsaturated subsoil. <br /> 13. Please define the terms minimal and nominal as used in Section <br /> D.6.5.1 when discussing potential leakage from the disposal facility. <br /> Please discuss how verification of losses will occur. <br /> RESPONSE: Please refer to the response to Question I1. <br />1 <br />I <br />1 <br />