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~~~ ~ • • 'RECEIVED <br />RESPONSES TO THE COLORADO MINED LAND $EP ~ $ 1992 <br />RECLAMATION DIVISION'S COMMENTS '-'' ''~~~'~' OF <br />ON BATTLE MOUNTAIN RESOURCES' ADEQUACY RESPOI~S~S~~'' d GEO~OG~ <br />TO TECHNICAL REVISION NO. 6 <br />RESPONSE TO COMMENTS BY HARRY POSEY <br />1. BMRI and its consultants have surmised, without supposing data, that the ground <br />water gradient directly beneath the tailings impoundments is westerly, on trend <br />with the surface [opograplay. Though reasonable, this is not proven. 77re <br />Division is concerned about the fate of any release from the tunings ponds. <br />Whether a release would flow into the Rito Seco, the Culeubra (sick, or to ground <br />water unrelated to these drainages is not known. <br />BMRI needs ro ident~ the likely fate of a potential release from the tailings pond <br />mrd establish routine sampling in. that area. <br />RESPONSE: The identification of the pathway that any potential release would take from the <br />tailings pond is addressed in the second phase submittal associated with Technical <br />Revision No. 8 (the additional wells have established the local ground water <br />gradient and site-specific aquifer hydraulic characteristics) and Technical Revision <br />No. 9 (which provides for containment of both surface and ground waters that <br />would be contaminated if a release occurred). BMR proposes that monitoring <br />wells installed as part of Technical Revision No. 8 be included in tPoe monitoring <br />described in Technical Revision No. 6; therefore, we believe that qhe Division's <br />concern identified in this comment has already been addressed. <br />2. The Division expects that once the hydrologic gradient in the vtciniry of the <br />tailings ponds is established, an appropriate number and appropriate types of <br />sampling stations will be established. <br />RESPONSE: BMR agrees with this concept, as evidenced by information provided in the <br />second phase submittal for Technical Revision No. 8. <br />3. The Division expects that sample containers, reagents, and ivarh solhtions will be <br />supplied by the third party scrrnplers. The Division.funher arpects that nccess to <br />monitoring wells will be strictly controlled by BMRI. <br />RESPONSE: The Memorandum of Understanding between the Colorado Division of Minerals <br />and Geology and BMR concerning third party verification sampling and the <br />