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<br />ROCKY MOUNTAIN CONSULTANTS, INC. ~~~ <br />Premiere Building <br />825 Delaware Avenue, Suite 500 <br />Longmont, Colorado 80501 <br />Metro (303) 665-6283 <br />April 22, 1999 FAX (303) 772-5282 <br />E-mail rmclong@rmii.com <br />Ms. Lori Potter <br />Kelly/Haglund/Garnsey & Kahn <br />1441 18"' Street, Suite 300 <br />Denver, Colorado 80202-1255 <br />RE: REVIEW OF h1ARCH 22, 1999 BATTLE MOUNTAIN RESOURCES, INC, SAN LUIS <br />PROJECT DOCUMENT "TR-26 WATER MANAGEMENT IN THE WEST PIT AREA" <br />Dear Lori: <br />Rocky Mountain Consultants, Inc. (RMC) has reviewed the March 22, 1999 Battle Mountain <br />Resources, Inc. (BMRI) document entitled "TR-26 Water Management in [he West Pit Area, San Luis <br />Project, Costilla County, Colorado." RMC performed our review at the request of Mr. Mike <br />McGowan of the Costilla County Conservancy District (CCCD). Our comments on this document <br />are provided below. <br />GENERAL COMMENTS <br />1. The document does not contain sufficient data to independently verify it's conclusions and <br />t,~ recommendations. Specifically, only time-series chemical data are presented for manganese <br />and sulfate, while the screening level risk assessment (Appendix D) presents only summary <br />statistics for Rito Seco chemistry data. Absent the raw historical chemistry, stream flow, and <br />groundwater level data, it is difficult to assess the adequacy of the proposed monitoring plan <br />presented in Section 6. <br />While the current surface water standard exceedences may be limited to sulfate and <br />ho manganese, trend analysis should be performed on all parameters to identify If increasing <br />trends are present in additional parameters that might pose future exceedences. <br />3. Although the document is not clear on the duration of the "long-term water management <br />'' plan", it appears that BMRI is proposing to install what can be essentially described as a <br />large-scale pump-and-treat system, and subsequently operate this system in perpetuity. <br />Given the unknown time frame over which this system must perform, it is in interest of the <br />CCCD and all downstream water users for the BMRI to implement a remedial action that is <br />effective, redundant, and has associated low operation and maintenance (O & M) costs. <br />While the proposed system appears to be effective, it has limited redundancy. Although no <br />cost analysis is presented in the document, we anticipate that the system proposed by BMRI <br />will have high O & M costs. <br />CIVIL AND ENVIRONMENTAL ENGINEERING • PLANNING <br />