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~ iii iiiiiiiiiiiiiiii <br />November 28, 1989 <br />Mined Land Reclamation Board <br />Dept. o£ Natural Resources, State of Colorado <br />215 Centennial Bldg., 1313 Sherman St <br />Denver, CO 80203-2273 <br />Dear Sirs: <br /> <br />R~~~~~~~ <br />DEC 1 1989 <br />MINED i.ANu <br />RECWMATION DIVISION <br />Please accept this letter as a listing of my concerns regarding <br />the Battle Mountain Gold Company amendment for Mining Permit No. <br />M-88-112. The reference in brackets at the beginning of each <br />paragraph refers to the amended mining plan section, otherwise the <br />page number is referred to. <br />1. [D.2] The stability of the East Pit wall due to its <br />closeness to the Rito Seco Creek is questionable. The possibility <br />of any dewatering of the Rito Seco must not be allowed. An <br />augmentation plan for lost creek waters is not satisfactory. Amore <br />thorough study must be conducted. <br />2. [D.3.2.1] The South Waste Rock Disposal Area and Waste <br />Rock Disposal Area D represent about 167 acres of disturbed flats <br />and woodlands which are perilously close to the Rito Seco. This <br />creek is only 700-1000 feet away from the respective sites <br />mentioned. The long-term leaching of materials including heavy <br />metals into the creek and into the aquifer is a distinct <br />possibility. <br />3. Pg D-12: Regarding seismic loading, can "slope failure to <br />assume a less steep configuration" cause rock and debris to enter <br />the Rito Seco? <br />4. [D.4.2] Dust control at the primary crusher will be a <br />source of air pollution, the likes of which is unknown in the San <br />Luis area where visibility is generally in the 50-70 mile range. <br />5. [D.5] What are the guarantees that there is "no potential <br />for cyanide solutions in the mill to discharge to the environment"? <br />The entire process of the mine plan must be a fail-safe design so <br />that any spills from operator error would be safely contained. <br />6. Pg. D-14: What is the "inert flocculent"? What is the <br />concentration of the "dilute cyanide solution for leaching"? What <br />-1- <br />