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<br />~ III IIIIIIIIIIIIIIII s~ti~ Li '..iii' °.~~=,•~,_~,~ <br />MINED LANt~ HECLAMAT IOV JIv15l~r~ ' ; ~ ~-.-.. <br />Department of Natural Resourws n; r., <br />1313 Sherman St.. Room 215 C' . <br />Denver. CO 80203 <br />303 866-3567 ~ ~ •'ra ie' <br />Fnx 303 832-6106 ~ O'~ <br />~ V E Vti ` RoY Rort~.ar. <br />_ / Governor <br />J ~ / Michael B. Lo ny, <br />/ L^ ` G J7 ! ~ D,v~sion Director <br />DATE: May 7, 1992 UI' <br />70: Mike Long <br />/' - ~'- , <br />FROM: Jim Pendleton ~~ =\ ~~ <br />RE: Comments on~"Draf/t,~~'t)ice of Violation and Order for Battle Mountain <br />~rces. Inc." <br />I have reviewed the DRAFT NOV and MLRB Order forwarded by Frank Jo nson. <br />I found one section with which I am concerned. I disagree with Fr nk's <br />wording of subsection "21, c.", the final clause of the order. In this <br />instance, I believe the proceedings were confusing and Maxine Stew rt's <br />statements were vague. Therefore, I believe it is appropriate to sk Ms. <br />Stewart to further clarify her intention. <br />Maxine was responding to the citizenry's request that "third party <br />environmental sampling be required. Several individuals had expre <br />distrust of Battle Mountain Resource conduct of the sampling progr <br />the hearing. My proposed abatement requirement item (12) imposed <br />"Modification of Monitor Sampling and Analysis Protocol" upon Batt <br />Gold. In earlier abatement requirement item (3), we impose an "Ac <br />Frequency of Environmental Monitoring", in that we require BMG to <br />accelerate their collection of samples from monthly to bi-weekly <br />weeks), until relaxation is approved by the Division. It was my i <br />continue requiring this accelerated frequency until the Division i <br />that the monitoring is accurate and we are convinced the tailings <br />method will succeed in bringing the cyanide content of the tailing <br />compliance with the permit standards. <br />during <br />Mountain <br />lerated <br />mporarily <br />ery two <br />ention to <br />satisfied <br />eatment <br />pond into <br />I understood that Ms. Stewart intended to impose third party verification upon <br />BMG. I assume that she also intended to reiterate the proposed to porary <br />acceleration of sampling frequency. I recognize that her statemen at the <br />hearing was vague. I fear that the order might be construed, as w rded, to <br />impose permanent third party sampling on a bi-weekly frequency. T is would be <br />extremely cumbersome, expensive, and might relieve erator fr m ~ f~ G ~~ <br />responsibilil~for monitoring _ This was de finitely not my intenti n. - ~ <br />I interpret third party verification to imply the random use of a hird party <br />to sample and analyze the environmental monitoring facilities at t e mine. <br />For exampiz, I foresee BMR nominating consultants and analytical 1 boratories <br />to f~~lfill the third party functions. The Division would approve r reject <br />ina G:`~il;lcc>, Uniil ac r;; table parties had been approved. The Division would <br /> <br />