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<br />• Page 5 <br />Dec~mber 14, 1998 <br />BMRI's own data, as summarized in Table 2 indicates that, lacking a significant decrease in <br />Sulfate levels in M-11 R, by the December 16°1 hearing date an ongoing violation of at least 75 days has <br />occurred. <br />2) Additional Wells <br />According to the November "TR-15 Response Plan", following a September 28" meeting <br />between BMRI, its consultants and the DMG, BMRI began to collect additional water quality samples <br />from groundwater wells "not previously designated for ongoing monitoring."12 <br />Test results from wells in the backfill and the pd wall were taken between October 1~' and 5" <br />registering TDS and Sulfate levels in violation of permit standards. BF-2 had a Sulfate oncentration of <br />1369.5 mg/L and a TDS level of 2293 mg/L. PW-1 had a Sulfate level of 1257.5 /L and a TDS <br />concentration of 2105 mg/L. An additional well in the backfill (BF-1) was found to hav a Sulfate level <br />of 245.5 mg/L and a TDS concentration of 546 mg/L, both within permit standar s, but certainly <br />elevated. <br />BF-2 is a 57 ft deep well into the west pit backfill. The purpose is a baseline ell. PW-1 is a <br />47 ft. deep well. It penetrates into the Rito Seco Alluvium; its purpose is to monitor pi stability. BF-1 <br />like BF-2 is a baseline well in the west pit backfill, its depth is 82 ft. <br />3) Summary <br />There appears to be a trend in ground water samples within the backfill o the pit and at <br />localized sites in the Rito Seco Alluvium downgradient from the west pit. Elevated le els of TDS and <br />Sulfates have been identified consistently since July of 1998. These Vends have not y t been detected <br />in the few deep wells in the vicinity of the west pit The duration of permit violati ns detected in <br />compliance ground water monitoring wells are concurrent. The longest active TDS viol lion will be 161 <br />days old on the hearing date while the ongoing Sulfate violation will be 75 days old. Additional <br />violations in wells not designated as compliance wells will have been collected 66 days eadier. It is no <br />longer "pre-mature" for the MLRB to issue BMRI with a violation. Compliance with r levant statutes, <br />regulations and permit conditions has cleady been neglected, the time is ripe to issu a violation and <br />appropriate fines . <br />B) Surtace Water <br />The November "TR-15 Response Plan" incorrectly states that, "at no time hale the in-stream <br />values exceeded stream standards for the Rito Seco."" As our summary describes, ince as early as <br />1994 Manganese concentrations in the Rito Seco have not complied with state water q ality standards. <br />Furthermore, TDS and Sulfates levels in the Rito Seco have become drastically ele ted in the past <br />year. TDS and Sulfate have been rising in concentration since as early as October o 1997, although <br />not yet violating in-stream standards. BMRI's monitoring efforts have provided ampe evidence that <br />water quality conditions in the Rito Seco have been altered within the localized a a of the Mine, <br />reflecting changing trends in TDS and Sulfates that do not exist at BMRI's upstream m nitoring station. <br />The November TR-15 Response Plan also reports that surface discharge o~he banks of the <br />Rito Seco has occurred. Groundwater from the west pit has surfaced and communi ed with the Rito <br />Seco. Water samples taken from this discharge indicate that it was above permit con ,lions for at least <br />three separate parameters. <br />1) Rito Seco Creek <br />~' BMRI, November 1998, TR-IS Response Plan, Page 2. <br />~' BMRl, November 1998, TR-15 Response Plan, pale I5. <br />