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<br />CMLRD reporting the results from the additional drilling, testing and modelling." <br />As such, BMR has already agreed to submit the documentation from the second <br />phase to the CDMG, which was done on August 6, 1492 (in a report entitled <br />"Mod~cntions of Existing Ground Water Maritorirrg System, Snn Luis Gold <br />Project, Castilla County, Colorado "J. <br />3. There is no frequency specked for the proposed sampling of the prang discharge <br />from the ground water containment wells in car junction with a ground water <br />renrediation program. 77rere is rro indica[ion of which fnnns of c}~nnide world 6e <br />detern:ined. <br />If the Quality Assurance/Quality Crnrtrol Protocols cover frequency of smnpling <br />and analysis of cyanide under uch circumstances, a more specific r%rence <br />should 6e provided. Otlrcnvise, a sampling fi•equcncy and cyanide analysis <br />should be indicated. BMR should also commit to cnntimrmion of such sarnplirrg <br />and analysis until the Division rc/eases them front the requircnrcnt. <br />RESPONSE: In the event that a ground water containment program would need to be <br />implemented, required sampling frequency would be developed on asite-specific <br />basis. This proposed sampling frequency would be submitted to the CDMG for <br />its review and approval prior to implementation. To eslablislt the frequency at <br />this time could not take into account the magnitude or the scope of any potential <br />containment program. BMR would propose establishing a sampling frequency <br />schedule, as necessary, based on the scope and magnitude of the containment <br />project. Ii is anticipated, however, that cyanide analyses from any contaimnent <br />project would be for total cyanide and weak acid dissociable cyanide. <br />4. 77:e positions of the approved ground water contaimnent well series will be frred, <br />presumably within a few hundred feet of the tailings facilities. It is conceivable <br />that a substantial surface release of cyanide-laden tivater from the facilities, <br />following the local drainage, might tarty beyond the ir~uence of the approved <br />ground water contaimnent wells before ir~lrrating and percolating to the level of <br />local ground water. Nothing in the proposal, as presented, considers and <br />evahrates the possibility of such an event or proposes arty approprinre interception <br />and/or containment measures. <br />BMR should develop and include, as pan of this technical revision, an evaluation <br />of this possibility and a description of what, if arty, nteanrres umuld be necessary <br />and taken to deal with suds a situalior:. <br />RESPONSE: ICHA's submittal in connection with TR-09 describes Battle Mountain's proposed <br />response to a surface flow, which would be in accordance with Section 9.1 of the <br />-z- <br />