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. III IIIIIIIIIIIII III - ~ <br />999 / ~ / A~~~ <br />June 15, 1992 , / ~ <br />Mssrs. Dean R. Massey and Mark N. Semenoff <br />Parcel, Mauro, Hultin and Spaanstra, P.C. <br />1801 California St Suite 3600 <br />Denver, co sozoz-6aoo h,~N IN : C~e1CYRfSP.LT(~ <br />RE: Comments on BMR's "Response to Adequacy Comments ooh Technical <br />Revision No. 006, Sampling and Analytical Protocol" Prepared <br />and received June 12, 1992; Battle Mountain Resdurces; San <br />Luis Project; Permit No. M-88-112. <br />Dear Mssrs. Massey and Semenoff: <br />The following are follow-up comments regarding the above cited <br />document. Comments are numbered according to you response <br />numbers. Upon receipt of adequate responses, the Divis~on will be <br />able to approve the Sampling and Analytical Protocol. <br />Regarding the choice of an "outside" independant lab to conduct the <br />monitoring, I have reviewed the SOQ of Water Waste and Land, Inc. <br />The SOQ appears to be current as of September, 1990. ~f you wish <br />for the Division to consider this company, you shoul¢i submit a <br />current SOQ, and in it specify the personnel and qualifications of <br />those who will be conducting the sampling. The choice of outside <br />party is not addressed by this letter. <br />COMMENTS: <br />1. Respondent has correctly identified my mistake; tq wit: RS-5 <br />is the station that should have been cited in this section. <br />BMG and its consultants have surmised, without supporting <br />data, that the groundwater gradient directly beneath the <br />tailings impoundments is westerly, on trend with tlhe surface <br />topography. Though reasonable, this in not proven. The <br />Division is concerned about the fate of any release from the <br />tailings ponds. Whether a release would flow into the Rito <br />Seco, the Culebra, or to groundwater unrelated to these <br />drainages is not known. <br />BMR needs to identify the likely fate of a potential release <br />from the tailings ponds and establish routine sampling in that <br />area. <br />2. The Division expects that once the hydrologic gradient in the <br />vicinity of the tailing ponds is established, an appropriate <br />number and appropriate types of sampling stations will be <br />established. <br />3. The Division expects that sample containers, reagents, and <br />