Laserfiche WebLink
,,''i1N-18-'1999 FRI 01:39 PM K/H/C & K LLC FAX N0. 3032938705 <br />• Michael Long <br />June 18, 1999 <br />Page 2 <br />P, 03 <br />Again, the failure to have adequate information on augmentation issues or <br />resolving such issues renders the ES inadequate, and the DMG approval of the <br />ES in light of such incompleteness is improper. Further, inasmuch ass the ES <br />was part of BMRI's TR-26 response, CCCD should have received the ES plan, <br />and an opportunity to comment thereon, pursuant to the Board's order of <br />January 26, 1999. DMG's failure to do constitutes a violation of the Board's <br />order. <br />C. Adequacy Letter Response to Comments of Rocky Mountain Consultants, <br />Inc., ("RMC") Comments on Monitoring Plan, Item 2.1 <br />The screening level risk assessment presented in Appendix D of TR~26 uses the <br />total recoverable form of iron to characterize aquatic risks (see Table 5 of TR-26 <br />Appendix D), and the total recoverable form of all metals, except iron and <br />• manganese, to characterize agricultural and drinking water risks (see Table 6 of <br />TR-26 Appendix D). For these reasons, RMC believes that surface water <br />samples should be analyzed for total recoverable metals as well as dissolved <br />metals. <br />RMC believes that it is premature to reduce the frequency of monitoring at <br />surface water station RS-5 from weekly to bi-weekly. Bi-weekly sampling, at a <br />minimum, is necessary until such time that Battle Mountain Resources, Inc. can <br />statistically demonstrate that the proposed remedial actions have ameliorated <br />water quality in the Rito Seco downstream of the mine site. <br />D. Adequacy Letter Response to RMC's "Specific" Comments <br />Page 18, Second Paragraph - <br />Mr. Posey states that background manganese concentrations at surface water <br />station RS-3 "should" be evaluated. Will they? <br />Page 20, Section 4.4,4.2 - <br />• The use of a physical barrier to inhibit the flow of water out of the West <br />PU901.061vro,nVlr OMG re ad"q~ccy.-p0 <br />