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~II'II'I~I~IIII~~II~ ~ ~ ~_ <br />STATE OF t <br /><"- <br />~~ ~~ <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />1373 Sherman St., Room 275 <br />Denver. CO 80203 <br />303 866-356% <br />Fn x: 303 832-8106 <br />July 8, 1992 <br />Mr. Gary Dodson <br />Battle Mountain Resources, Inc. <br />P.0. Box 310 <br />San Luis, Colorado 81152 <br />Re: San Luis Project, Technical Revision No. 009, Adequacy Comments <br />Permit No. M-88-112 <br />Dear Mr. Dodson; <br />Mkhael B. Long, <br />Division Drtettor <br />The Division has completed a "preliminary" technical adequacy review of BMRI's <br />technical revision application No. TR-009, which BMRI submitted to the <br />Division on June 15, 1992. TR-009 addresses the development of a "tailings <br />effluent leakage interception, containment and treatment plan to be <br />implemented in the event of contaminant migration from the tailings area", as <br />contained in Abatement Requirement tt6 of the Board Order of May 28, 1992. <br />In his cover letter to BMRI's application, Mr. Mark Semenoff of Parcel, Mauro, <br />Hultin & Spaanstra, appropriately observed that "the enclosed plan identifies <br />a Qeneral approach to develoDinq a around water containment plan..." Mark <br />characterized the plan development process as including two phases. The first <br />involves the additional data collection and characterization of the ground <br />water aquifer, as contained in BMRI's technical revision application No. <br />TR-008, approved June 29, 1992. The second phase, addressed in this technical <br />revision application No. TR-009, incorporates the additional aquifer <br />information along with existing data to finalize development of the required <br />containment plan. <br />For the above reason, it is appropriate that this technical revision <br />application be preliminary and general. It presents a proposed methodology <br />and references basic supportive information with which to finalize development <br />of the containment plan. In turn, the adequacy comments attached to this <br />cover letter, as forwarded by James C. Stevens, PhD. of the Division, and <br />Scott Mefford, hydrogeological consultant to the parties, are also general in <br />character. These comments understandably speak to methcdology for completing <br />the evaluation of data to be collected and the development of the plan, rather <br />than specific data or conclusions. As 'nas been our consistent approach, I am <br />forwarding Mr. Mefford's comments in their unabridged form for your <br />consideration and response. <br />As ordered by the Board on June 25th, 1992, the Division's June 29th approval <br />of TR-008 triggered the compliance deadlines contained in paragraph (3) of the <br />Board's additional corrective action order. Those additional imposed <br />compliance deadlines require the installation of two additional ground water <br />monitoring wells, well testing, data reduction and submittal of an evaluative <br />pE'COi <br />~~ q9 <br />,.r'ie" <br />. ~8i <br />~~~' . <br />" re'16 <br />Roy Romer, <br />Governor <br />