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~ III IIIIIIIIIIIIIIII ~ <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Del Llriminl D(i lulu rdl RPSOUrCPs <br />I31 S Sherman 51.. Room 215 <br />Denver, Colorado 8003 <br />Phone. 13031 855~35h7 <br />FAY. 1703) 83?-8105 <br />January 5, 2000 <br />DIVISION O F <br />MINERALS <br />GEOLOGY <br />RECLAMATION <br />MINING•SAFETY <br />Roger FI nn Bill pwens <br />y Gavemor <br />Western Mining Action Project ~ - ereg E. lval<her <br />2260 Baseline Rd, Suite IOIA Eee<unve Dlre<lor <br />M¢hael B. Long <br />Boulder CO 80302 Dinsion Director <br />Re: Response to Recent Comments, San Luis Project, M-88-112 <br />Dear Mr. Flynn: <br />The Division received and reviewed your letter of concern, dated December 2, 1999, which <br />focused on the following items: 1) piecemeal approach to site remediationlreclamation, 2) <br />bonding/financial assurance, 3) proposed West pit hydraulic barrier, and 4) waled management. <br />The Division will address each of these items in the same order as presented. <br />First, you are correct, the Division has issued partial approvals of Technical Revision 2b (TR- <br />26) during the past yeaz. This is in response to BMRI's requests to initiate various aspects of the <br />TR. The partial approvals were issued only after BMRI adequately addressed all the <br />technical/geotechnical issues involving compliance with the minimum requirements of the <br />Act/Rules. <br />The long-term solution to the water quality problems is cleazly outlined in TR-26. As currently <br />approved, BMRI will pump the West pi[ backfill at a sufficient rate to lower the water level to a <br />msl of 8580 feet. After which, the pump rate will be reduced to a steady state rate to maintain the <br />water level at 8580 feet msl. The pit water will be processed by an evaporation system for 5 <br />months and anano-filtration system for 7 months. BMRI will initiate a passive system pilot <br />project in the pink gneiss azea as soon as all the approvals have been issued (the DMG has <br />already approved the project). If the passive system proves to be successful, BMRI will submit a <br />sepazate proposal to utilize the carbon injection method to clean up the entire West pit which <br />would then define the long-term solution. However, if the passive system is unsuccessful, BMRI <br />will be required to continue processing the West pit water with the currently appnoved systems <br />(unless another method is proposed and approved) which would then define the long-term <br />solution. Currently, the DMG does not have an official proposal from BMRI to install a slurry <br />wall so, for now, this is not being considered part of the long-term solution by the DMG. <br />BMRI is still considering other alternatives in an attempt to meet the applicable water quality <br />requirements (eg. land application, etc.). However, these aze only in the evaluation stage. <br />