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<br />• Page 9 December 14, 1998 <br />2) Issue a permit violation to BMRI for the aforementioned discharge. <br />3) Issue a permit violation for standing water in the west pit. <br />4) Recognize that BMRI has at least temporerily violated the terms of it's Stormvyater Discharge <br />Permit. <br />5) Improve ground water permit condition values to ensure the protection of the beneficial uses of <br />the Rito Seco. The strictest applicable standards should be applied to grou d water in the <br />West. <br />6) Expand the number of proposed monitoring wells on the west pit as appropriate. <br />7) The DMG and MLRB must involve the Colorado Water Quality Commission in enforcement <br />efforts related to water quality violations and changes in water quality in the Ritq Seco. <br />B) Require BMRI to immediately instigate treatment of water and/or backfill in the west pit to <br />ensure the end of permit violations with regard to water quality. <br />9) Require BMRI to provide the CCCD with copies of all monthly water quality lab story analysis <br />results, and copies of the Hydrologic Characterization Report, Treatment esting Results, <br />Treatment Options Report, Hydrologic Modeling Report, Hydrologic 8 Charact rization Report <br />and Long-term Application Report To Agency as soon as such documents are provided to the <br />DMG. <br />10) Require a revised dewatering plan for the west pit <br />and <br />11) Require the development of new storrnwater management BMP's for the west pit to ensue <br />that adequate stormwater management is in place at all times. <br />We sincerely appreciate the opportunity to comment regarding the developingg~ situation at the <br />Mine. We look forward to discussing these issues in the future, specifically at the hearing scheduled for <br />December 16th. We expect to present our concerns at the hearing. Our presentation ay include oral <br />or written testimony from our Counsel, our consultants and/or of staff or board members/. <br />Sincerely, <br />,w:~.,.P ~'~ <br />Michael McGowan <br />Research Director <br />Costilla County Conservancy District <br />M-I IR Sulfa[e Violation, 75 days x 5100 or 1000 per day = 57,500 or 75,000. <br />