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<br />Costilla County <br />Conservancy District <br />December 14, 1998 <br />~II II~II~III~I~~ II~ <br />a01 Church Place <br />PO Box a2 <br />San Luis, CO 81152 <br />Ph'719.872-7213 <br />Fx: 719-fi72-0740 <br />I <br />_c,ho t rr~ <br />.~1 <br />Mr. Michael Long, Director ,. <br />Colorado Division of Minerals and Geology - - <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 ~''tr=' -`- ~' ~~'-1c':; <br />Re: Battle Mountain Resources Inc., San Luis Project, M~8-112 <br />Dear Sir. <br />This letter is submitted on behalf of the Costilla County Conservancy District (dCCD) regarding <br />our ongoing concerns with the Battle Mountain Resources Inc. (BMRI) gold mine (Min )outside of San <br />Luis, CO. We have been actively involved with issues associated with the Mine since it was proposed <br />in 1988. We are historic objectors to the mine because of concerns related to change in water quality <br />and the effects of such changes on downstream uses. The purposes of the ~CCCD are the <br />conservation and development of water for agricultural, municipal and industrial us s, regulation of <br />stream courses, and flood prevention. <br />We are aware that the December 16°i Mined Land Reclamation Board (ML <br />consider BMRI's recent permit violations. We are also aware that since Septembe <br />plans have been prepared on behalf of BMRI to address recent changes in water qua <br />interactions between the Mines west pit and the Rito Seco Creek. This letter details b~ <br />with conditions at the Mine site and the Division of Minerals and Geologys (DM <br />responses to these problems. We have reviewed the materials prepared by, of <br />additional water quality and hydrological information as was feasible considering the <br />time which we were afforded to respond. Additional expert opinions provided to the C <br />these matters will be presented by Scott Medford of Hydrokinetics Inc. during the <br />hearing. Mr. Medford is expected to request the installation of at least three additional <br />We reserve the right to submit additional analysis and comments as more infon <br />available or as the situation changes. <br />The recent developments surounding the west pit indipte that set <br />problems may be developing. Ground water standards, for at least one parame <br />solids - TDS), at M-11R have been actively violated since July 8, 1998. By the <br />violation will constitute an ongoing violation of at least 161 days. Furthermore, ste <br />levels within this well have been violated since October 2n°; by the permit hearing da <br />represent an ongoing violation of at least 75 days. Surface water quality standard v <br />occured within the Rito Seco over the past year. The post mining Manganese le <br />averaged well above state water quality standards. Finally, on October 28°i, BMRI <br />discharge into the Rito Seco Creek, a "water of the United States". The duration ar <br />discharge are not established as fact Water samples from the discharge indicate <br />permit conditions and state water quality standards. The best information available i <br />violations are a direct result of the Mine's actions and alterations of the hydraulic regi <br />tB) hearing will <br />two response <br />y and hydraulic <br />rh our concerns <br />3) and MLRB's <br />far, BMRI and <br />short amount of <br />:CD concemin~ <br />December 16 <br />Monitoring wells. <br />ration becomes <br />e water quality <br />(total dissolved <br />oaring date, this <br />lards for Sulfate <br />this violation will <br />ations have also <br />Is at RS-2 have <br />ported an active <br />cessation of this <br />at it was beyond <br />hates that these <br />of the west pit. <br />We respectfully request that the DMG and MLRB take actions to ensure compliance of BMRI <br />with all statutory and regulatory requirements and hold BMRI completely accountadle for its actions. <br />CCCD Page 1 12114!98 <br />