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' ` ~ .. <br />i y.. <br />~~~~~' <br />ADEQUACY RESPONSES TO COLORADO DIVISION OF pCT 191992 <br />MINING AND GEOLOGY ADEQUACY COMMENTS <br />TO TECHNICAL REVISION NO. 9 - DIV15~u~'• v' <br />SURFACE WATER AND GROUND 1VATER CONTAINNIENTp~~fs ~ ~tU`V~=''r <br />RELATED TO POTENTIAL CONTAMINANT MIGRATION FROM11 TIIE <br />TAILINGS AREA, SAN LUIS GOLD PROJECT, <br />COSTILLA COUNTY, COLORADO <br />COMMENTS BY JAMES C. STEVENS <br />1. The drilling and testing of the additional monitoring wells approvers in TR-08, <br />comprising Phrase 1 of this proposal, will nor be completer! in tinte•(n~ evnluntian <br />o(the dnta, development of a ground water containment plan, and Division review <br />by the mandated decision data ojJuly I5, 1992 for TR-09. <br />BMR should waive their right to a decisirnt on TR-09 by July 15, 1992 ro provide <br />enougle time to assemble the data, evaluate, and p,•apase a ground water <br />containment plat that could be considered by the Divisiat f tr approval. <br />RESPONSE: BMR received acknowledgment of the acceptance of TR-08 on July 2, 1992. At <br />that time, BMR initiated the necessary tasks to comply with TR-08 and the <br />drilling and testing of the additional monitoring wells was completed during the <br />period July 20, 1992 through July 28, 1992. Therefore, Bt,4R leas agreed to <br />waive its right to a decision on TR-09 by July 15, 1992. <br />2. There is some doubt that the Division will be provided with Ilm results of Ilte <br />second phase, i. e., data evaluation, of the development of the propased ground <br />water containment plat. Tl~e cover leaer indicates "if necessat~~ ", nhhouglr Page <br />2 of the proposal conunits to submiaing this "documentation to CA~LRD ". <br />77te Division considers it necessary ro its determinations anti review ~( BMR's <br />proposed ground water co+ttaimnent plat, whatever that nmy be, that all testing <br />data, descriptions, modelling and evaluations made in crntjrutctiota tivith or leading <br />to BMR's proposal he provided. If this is not entirely agreeable to BA4R, i. c., if <br />there are conditions to submittal of this data on BMR's part, the proposal shrndd <br />clearly state these conditions. <br />RESPONSE: As stated in John C. Halepaska and Associates, Lie's (JCHA) TR-09 submittal, <br />"[f]ollowing the CMLRD approval of the program [TR-08] and its implementation <br />by Battle Mountain, Battle Mountain will submit separate docmnentation to <br />