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~- <br />' ADEQUACY RESPONSES TO COLORADO DIVISION OF ACT 19199 <br />MINIlVG AND GEOLOGY ADEQUACY COMMENTS „ ;.;,~i~ Ur <br />TO TECHNICAL REVISION NO. 9 - ,~gli;tnxL~ 8 3E~,i_i~(;Y <br />SURFACE WATER AND GROUND WATER CONTAINA1EN'l' PJ.AN <br />RELATED TO POTENTIAL CONTAMINANT I\1IGRATION FR011I 'f11E <br />TAILINGS AREA, SAN LUIS GOLD PROJECT, <br />COSTILLA COUNTY, COLORADO <br />COMMENTS BY JAMES C. STEVENS <br />1. The drilling and testing of the additional monitoring wells npprol>ed in TR-08, <br />comprising Phase 1 of this propnsnl, will not be completed in time firr evaluation <br />oftlre data, development ofa ground water containnrem plan, and Division review <br />by the mandated decision data of July 15, 1992 for TR-09. <br />BMR should waive their right to a decision on 7R-09 by July 15, 1992 to provide <br />enough time to assemble the data, evaluate, and propose a ground mater <br />contaimnent plan that could be considered by the Division fitr nppr•oval. <br />RESPONSE: BMR received acknowledgment of the acceptance of TR-08 on July 2, 1992. At <br />that time, BMR initiated the necessary tasks to comply with Tlk-08 and the <br />drilling and testing of the additional monitoring wells was completCd during tl+e <br />period July 20, 1992 through July 28, 1992. Therefore, BMR has agreed to <br />waive its right to a decision on TR-09 by July 15, 1992. <br />2. There is some doubt that dre Division wilt be provided with the resuhs r f dre <br />second phnse, i. e., data evaluation, of the development of dre proposed ground <br />water containment plan. The cover letter indicates "if necessary ", nhltouglr pnge <br />2 of the proposal canrnits to submitting this "documentation ro CA~LRD ". <br />77re Division considers it necessary to its derenuinarions and reviv+v of BMR's <br />proposed ground water contaimnent plan, wlmtever that tray be, thpt all testing <br />da[a, descriptiotu, modelling and evaluations made in conjunction will: or leading <br />to BMR's proposal be provided. If this is not entirely agreeable ro BMR, i. e., if <br />there ore conditions to submittal of dtis data on BMR's parr, dre proposal shrndd <br />clearly stale [hese cotrdi[iotrs. <br />RESPONSE: As stated in John C. Halepaska and Associates, Inc.'s (JCHA) TR-09 submittal, <br />"[f]ollowing the CMLRD approval of the program [TR-O8] and its implementation <br />by Battle Mountain, Battle Mountain will submit separate documentation to <br />