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<br />` CMLRD reporting the results from the additional drilling, testing and modelling." <br />As such, BMR has already agreed to submit the documentation from the second <br />phase to the CDMG, which was done on August 6, 1992 (in a report entitled <br />"Mod cations of Existing Ground Water Monira~ing system, $mr Lui.r Gold <br />Project, Costilla County, Colorado"). <br />3. There is no frequency specified for dte proposed sampling (the pump discharge <br />from tl:e ground water containment wells in conjunction with a ground water <br />remediation program. 7Trere is no indication of which forms of cypnirle would be <br />determined. <br />/f the Quality Assurance/Quality Control Protocols cower fiequcney of snnrpling <br />acrd analysis of cyanide under such circumstances, amore specific reference <br />should be provided. Otherwise, a sampling frequency and cyanide annlyris <br />should be indicated. BMR should also conunit to continuation tJ'such .rmnp/ing <br />and analysis until dte Division releases them from dre rcquirenrerrl,. <br />RESPONSE: In the event that a ground water containment program would need tv be <br />implemented, required sampling frequency would be developed on Rsite-specific <br />basis. This proposed sampling frequency would be submitted to the CDMG for <br />its review and approval prior to implementation. To establish the frequency at <br />this time could not take into account the magnitude or the scope of any potential <br />containment program. BMR would propose establishing a sampling frequency <br />schedule, as necessary, based on the scope and magnitude of the containment <br />project. It is anticipated, however, that cyanide analyses from any containment <br />project would be for total cyanide and weak acid dissociable cyanide. <br />4. 77re positions of the approved ground water containment well series will be fixed, <br />presumably widtin a few hundred feet of the tailings facilities. It is conceivnbte <br />drat a substantial surface release of cyanide-Inden water fi~an: tyre ,facilities, <br />following the local drainage, might carry beyond the ir~uence of the approved <br />ground water containment rvclls before ir~hrating and percolating to dre lcrel o/ <br />local ground water. Nothing in the proposal, as preserved, considers mrd <br />evaluates dre possibility of such an event or proposes any npproprinre interception <br />and/or containment measures. <br />BMR should develop mrd include, as parr of this technical revision, rnr ewnlrtntion <br />of this possibility and a description of what, if any, measures would be necessary <br />and taken to deal with such a siatation. <br />RESPONSE: JCHA's submittal in connection with TR-09 describes Battle Mountain's proposed <br />response to a surface flow, which would be in accordance with Section 9. I of the <br />-Z- <br />