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~ - . ~ ~ III IIIIIIIIIIIII III ~ .~ ~ = __ ~ ~,, ~.,~ <br />= ADEQUACY RESPONSES TO COLORADO MINED LAND UN 1 2 1992 <br />RECLAMATION DIVISION ADEQUACY COMMENTS TO ;4;ined Land <br />_ TECHNICAL REVISION NO. 6 - RQrI~~-~+in~ r+~ +••:~n <br />~ QUALITY ASSURANCE/QUALITY CONTROL PROTOCOLS <br />FOR THE COLLECTION OF SURFACE AND GROUND WATER QUALITY DATA <br />SAN LUIS GOLD PROJECT, COSTILLA COUNTY, COLORADO <br />l <br />,. COMMENTS BY HARRY POSEY <br />~ 1. There needs to 6e a sampling point on the Rito Seco dotivnstrecutt of the railings <br />e impoundment. The presetrt RS-S point is in a dry alluvial valley a»d yields no <br />water. 71te proposed san:pting point would need to be outside the permit <br />boundary. 1 recanmend a point just downstream of where tha light duty road <br />crosses tl:e stream, as s)torvrt on Figure 1 in t)te Protocol Proposal. <br />RESPONSE: Station RS-5 is not located in a "dry alluvial valley"; it is on a perennial reach <br />of Rito Seco and has been monitored on a quarterly basis since the pre-mining <br />period. BMR believes that Comment No. 1 is actually referring to Station RS-6, <br />which is located downstream of the tailings facility in a sub-basin tributary to Rito <br />Seco. This sub-basin is generally dry. We do not believe an additional <br />_ monitoring point on Rito Seco is warranted at this time, and the location proposed <br />"downstream of where the light duty road crosses the stream" is in a reach of <br />` Rito Seco that is not perennial, as the Salazar Ditch, at times of the year, diverts <br />- all of the flow in Rito Seco. Additionally, it has been previously established that <br />~ the dry reach below the tailings facility does not Flow into the Rito Seco but, <br />rather, flows south when it exits the canyon and flows to Culebra Creek. <br />- Therefore, the proposed location is not downgradient Of the tailings <br />_ impoundment. <br />- 2. Although many moni[or wells have been installed, only three rourbrcly yield water <br />_ enough for sampling: M-4 mtd M-10 on the Rito Seco, and Af-9 west of the <br />tailings impoundment area. Altltoug)t M-9 is apparently dotvrpgradiertt of the <br />_. tailings ponds, M-4 and M-10 are also down gradicru of the tailings. Wlretlter <br />- a teak from the tailings would flotiv toward die nortlt (toward M-d and M-10), or <br />whether it would flow toward dte west (toward M-9J, or whedrer it would flow in <br />- other directions camrot be detemrined either fran the penttit or from d:e <br />- Monitoring Protocol Proposal. <br />~ The April 1992 NOV Abatement Plan calls for sampling M-2, M-$, M-7, M-8 and <br />M-9. However, because M-2, 6, 7 and 8 are dry, and because rve do not know <br />-1- <br />