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+r <br />I1~ <br />• <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />De <br />ar(menl of Nalu <br />! R <br />OF'CO~ <br />p <br />ra <br />esources <br />1313 Sherman Sl., Room 215 A~ <br />~ <br />Nei <br />~ <br /> <br />Denver, CO 80207 . <br />Phone: (303)866-3567 'lab' <br />FA%.(3031832-8106 <br /> Roy Romcr <br /> <br />November 2, 1993 Governor <br />nlichael 8. long <br /> Division Director <br />Mr. Ken Kluksdahl, Operations Manager <br />Battle Mountain Resources, Inc. <br />P.O. Box 310 <br />San Luis, CO 81152-0310 <br />RE: Division Review Comments, BMRI - October 13, 1993, Construction <br />Status Report, San Luis Project Tailings Area, Phase II, Raise I, <br />File No. M-SS-112 <br />Dear Mr. Kluksdahl: <br />On October 18, 1993 the Division received the above captioned report <br />which was prepared primarily to address issues raised by the Division <br />in a meeting held on October 8, 1993 and identified during previous <br />reviews of BMRI submittals and the September 30-October 1, 1993 <br />Phase II inspection. Allen Sorenson of our office completed a <br />technical review of your report, <br />There are three construction activities of Phase II that the Division <br />has concerns about, the embankment raise fill, drainage blanket, and <br />compacted soil liner (liner sub-base). Mr. Sorenson's concerns are <br />shown below. Please review them and provide appropriate responses <br />paying particular attention to those portions that are underlined. <br />DISCUSSION <br />The Division believes that there are two components of any liner <br />system that are integral to containment, they are: <br />1. A composite liner system consisting of a low permea:oility soil <br />liner directly overlain by, and in intimate contact with, a <br />geomembrane. <br />A method by which the hydrostatic head on the composite liner can <br />be minimized. <br />One of the reasons that the Division did not require a more verifiable <br />head minimization system at the San Luis facility, such as geogrid <br />sandwiched between two geomembranes for leak collection and removal, <br />was BMRI's assurance that the tailing liquids, (the fluid intended to <br />be collected by the drainage blanket), would be low in cyanide. The <br />early failure of the AVR system to eliminate cyanide from the tailing <br />entering the impoundment, has created a situation where a considerable <br />volume of high cyanide fluids may be migrating through the tailing <br />pile. <br />It is now evident that the hydraulic conductivity of the drainage <br />blanket is lower than was anticipated by the design engineer. This <br />