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<br />PARCEL, MAURO, HULTIN & SPAANSTRA, P. C. <br />Dr. James A. Pendleton <br />June 15, 1992 <br />Page -2- <br />identified in the modified groundwater monitoring plan and collect additional aquifer <br />characteristics data. During the second phase, BMR will incorporate the additional aquifer <br />information with existing data and determine additional groundwater contai~tment measures, <br />including additional well placement, if any. As noted above, if necessary„ehe results of this <br />second phase will be reported to the Division. ~ ~~ ~~. ~ <br />~: , <br />As noted above, the focus of the proposed plan is on groundwater containment. <br />BMR believes that, based on the conservative design assumptions under Which the tailings <br />facility was constructed, the focus on groundwater containment is apprgpriate given the <br />reduced risk of a surface water release and any attendant soil contamination. Furthermore, <br />the proposed plan incorporates by reference the San Luis facility's Emergency Response <br />Plan which was approved by the Division as part of Permit No. M-88-11~ (Appendix M). <br />As you know, the Emergency Response Plan specifies procedures which San Luis facility <br />personnel would take in the event of certain types of spills or other releases. <br />We look forward to resolving any outstanding issues and obtaining final approval of <br />Technical Revision No. 009 as soon as possible. Thank you. <br />Very truly yours, <br />PA~IR,C/E~L~MA/U/~RO, HULTIN STRA, P.C. <br />Mark N. Semenoff <br />Attorneys for Battle Mountain Re9ources <br />MNS:Iv <br />Enclosures <br />cc (w/encls.): Costilla County Conservancy District <br />Helen Sigmond, Esq. <br />People's Alternative Energy Services <br />Nora Jacquez <br />Dave Hyatt <br />Jane I. Kircher <br />Scott Mefford <br />Gary Dodson <br />Walt Wise, Esq. <br />Andre Douchane <br />