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<br />38. Please describe the chemical composition of the water contained at the <br />collection pond and on the tailings surface. If the chemical analysis <br />indicates that these waters are toxic to waterfowl, Battle Mountain must <br />submit a plant to minimize waterfowl contact. In addition, a deer and <br />elk proof fence around the collection pond may be necessary, depending <br />upon the potential toxicity to wildlife, and to ensure liner protection. <br />Exhibit E, Reclamation Plan <br />39. It is apparent that detoxification and/or treatment of the tailings <br />material after deposition will be impossible. Therefore, any necessary <br />treatment of the tailings material must be accomplished prior to <br />deposition. In order to determine what, if any, treatment is necessary, <br />geochemical analysis of the material at the point of deposition must be <br />provided. <br />In order to judge whether treatment is necessary, a criteria for <br />evaluation must be established. Our analysis indicates that any seepage <br />or flaw form the facility would most likely infiltrate into the <br />colluvial material a short distance from the disposal facility. <br />Therefore, the adopted groundwater standards are applicable to the <br />effluent from the facility. Battle Mountain must demonstrate that <br />impacts to the hydrologic balance are minimized after reclamation is <br />complete. A predictive model of the effluent, given post reclamation <br />conditions and the geochemical characteristics of the tailings, should <br />be submitted. If the model suggests treatment of the tailings prior to <br />deposition is necessary, a plan to do so should also be submitted. <br />40. The final topography on the tailings surface is described as being <br />created by selective deposition at the end of operations such that only <br />minor grading is expected prior to topsoil placement and revegetation. <br />It is noted in Appendix L (Spillway Design Calculations) that ".... the <br />reclamation plan may spigot clean material and seed, rather than using <br />earth movers to grade the surface." Please clarify the method proposed <br />for topsoil distribution and seeding on the tailings surface. <br />41. In order to encourage drainage form the reclaimed surface of the <br />facility, a grade in excess of 0.5% should be created. We recommend that <br />a 1.5% grade be established. This grade would facilitate the removal of <br />water from the surface of the facility in a non-erosive manner, while <br />minimizing the potential for ponding and infiltration to occur. <br />-5- <br />