ENFORCE37810

• Permit No: M1988112
• IBM Index Class Name: Enforcement
• Doc Date: 8/11/1992
• Doc Name: STATUS OF COMPLIANCE BMRI SAN LUIS PROJECT TAILINGS PONDS PN M-88-112
• From: MLRD
• To: PHILIP M HOCKER
• Media Type: D
• Archive: No

Letter to Philip M. Hocker, MPI
Status of Compliance of BMRI
page 2
treatment process on July 30, 1992. The installation of the INCO
process equipment is scheduled to be completed by the end of
September, 1992. Further, immediately following INCO im lmentation
BMRI is required to treat both tailings ponds to brin them into
compliance with the original permit cyanide standar s (4.4 ppm
total cyanide and 3.8 ppm WAD cyanide) as soon as po Bible. In
contrast to your conclusion, I believe that the Divis on (State)
has adopted a stringent approach to the seriouness an timing of
BMRI's response to this situation.
In the third paragraph of your letter to Luke Da ielson you
observed that you were also concerned because "there ap ears to be
no action taken, or planned or proposed, to assess the antity and
concentration of cyanide which has been deposited in t e tailings
slurry". Abatement requirement #8 of the attached M y 28, 1992
Board Order specifically requires BMRI to c mplete a
recharacterization of the long term chemical consitue cy of the
tailings. Further, if appropriate, BMRI is required to modify its
existing reclamation plan for the tailings embankment.' I contend
that the MLRB and the Division have indicated that an evaluation of
the entire chemical constituency of the tailings,i far more
comprehensive than evaluating cyanide content alone, i necessary
before the issue of final disposition of the tailings st ucture can
be appropriately resolved.
I appreciate the fact that you have demonstrated an ~nterest in
Battle Mountain Resource Inc.'s (BMRI's) San Luis Projec since our
earlier consideration of Amendment #1 in 1989. I ecall our
telephone discussion of several months ago. Please be a sured that
I and the Division value all comment received from kn wledgeable
and involved individuals such as you. In that regard, should you
desire to visit the site, I would be glad to assist you in
obtaining access to the site. If my schedule can be amended, I
could also accompany you to the site. BMRI has been r ceptive to
interested parties visiting the San Luis site. As ou may be
aware, BMRI recently hosted a site visit by members of the Board,
the Division, the parties to this action, and technical onsultants
to the parties. I am confident BMRI would acco odate any
reasonable request you might make.
If I can be of any additional assistance in facilit ting your
consideration of the San Luis situation or any of er mining
operation within our jurisdiction, please do not h sitate to
contact me. It would be my pleasure to assist you in ormulating
a comprehensive and informed understanding of our regulatory
program.