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~II II~~II~I~~~~~ ~I~ <br />MINED LAND RECLAMATION DIVISION <br />Department of Na[ural Resources <br />1313 Sherman S7.. Room 215 <br />Denver, CO 80203 <br />303 8663567 <br />FA %303 832-8106 <br />STAT~OF COLORADO <br />s <br />pF CprO <br />ti~~ ~~ <br />/e'!6 ~ <br />Roy Romer, <br />Governor <br />Michael B. Long. <br />June 30, 1992 Gw~s~on Director <br />Andre' Douchane <br />Vice President, Compliance <br />Battle Mountain Resources, Inc. <br />5670 Greenwood Plaza Boulevard, !>`106 <br />Englewood, Colorado 80111 <br />Re: Compliance with the Board Order of June 25, 1992 <br />Dear Mr. Douchane; <br />As you are well aware, the Board issued additional corrective actin s in the <br />form of an Order on June 25, 1992. Canci'd1y, that Order contains s me <br />relatively innovative directives, both to Battle Mountain Resources Inc. and <br />to the Division. <br />In paragraph (1) of the Order, the Board placed a WAD cyanide compliance level <br />of 50 ppm on BMRI as of July 3, 1992, next Friday. In paragraph (2 the Board <br />ordered BMRI never to allow the tailings pond WAD cyanide level to ise back <br />above that 50 ppm level. In paragraph (3), the Board set time limi s upon <br />implementation and completion of various components of BMRI's TR-00 which <br />was approved yesterday. <br />In paragraph (4) the Board ordered BMRI to continue to use "its bes~ efforts" <br />to lower the cyanide levels in the tailings pond to "the lowest rea onably <br />achievable levels". The Board also provided a "target level of 35p m" to be <br />achieved two days before the July Board meeting, on July 20th, 1992. However, <br />the Board directed BMRI not to stop at 35 ppm, but to continue to 1 wer the <br />cyanide levels in the tailings pond. This is relatively straight f rward. <br />However, the Board also directed "the staff, or other parties" to r turn to <br />the Board to seek further action against BMRI, if at any time they 'believe <br />that BMRI is not doing everything reasonably practical" to reduce t e cyanide <br />levels to the lowest reasonably achievable levels. <br />While the Division has never wavered from our regulatory responsibilities, we <br />have rarely been directed to pursue enforcement actions on the meri of <br />belief. Candidly, because of my concern regarding this directive, nd because <br />of recent inquiries from your staff, I believe it prudent to forwar the <br />following observations. <br />