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<br />Now that BMRI is allowed to discharge processed water into the Rito Seco (fronp the nano- <br />filtration system) the primary goal of TR-26 seems to be moving forward. As of December, 1, <br />1999, the water level in the West pit has been lowered to a msl of 8592 feet in just a few months. <br />Continued pumping of the backfill aquifer will result in a water level of 8580 feet msl in just a <br />couple more months (estimated at 56 days at a rate of 400 gpm). Water sample test results from <br />the backfill monitoring wells indicate that the water quality in the West pit appears to be <br />improving; at least for manganese, sulphate and TDS, which is good news. The arithmetic <br />average of manganese, sulphate and TDS in January, 1999 for 5 backfill wells (BF-2, BF-3, BF- <br />4, BF-5 and BF-6) was 6.27 mg/I, 818 mg/I and 1346 mg/I respectively. In October, 1999, the <br />average was 3.93 mg/1, 680 mg/1 and 1000 mg/I respectively for the 5 wells. Realizing this is <br />early on in the clean up process, and conditions can change as seasons change, i[ does appear that <br />the approved processing systems are slowly correcting the problem as TR-26 was designed to do, <br />and that the partial approvals were justified. <br />Second, the Division still agrees that the site must be fully covered by financial assurances and <br />the Division is diligently working towazd that end. Attached is a draft copy of the required tasks <br />and cost estimates for the remaining reclamation obligations at the San Luis Project (this does <br />not include the estimated West pit water management costs; they will be submit[@d separately). <br />For now, the DMG is not evaluating [he cost of a slurry wall because, as previously noted, this <br />type of structure has not been proposed to, or approved by, the DMG. <br />The DMG is aware of Rule 4.2.1 and will take into account all expected costs of teclamation and <br />will ensure that the amount of financial warranty shall be sufficient to fulfill the applicable <br />requirements of the reclamation plan which will include measures to protect water resources. <br />Third, as previously mentioned, BMRI has not submitted a proposal to install a slurry wall in, or <br />near, the West pit. There have been discussions between BMRI and the DMG regarding the <br />installation of a slurry walUhydraulic barrier, but no official proposal. It is just another alternative <br />being considered by BMRI. <br />Fourth, transportation of West pit water to the tailings impoundment was approved to allow <br />BMRI to initiate a continuous pumping operation at the West pit in order to meet one of the <br />requirements of TR-26; which is to lower the water level in the backfill material. BMRI did not <br />have enough room at the West pit facility to store all the water that was being purytped since the <br />processed water (from the nano-filtration unit) could not be dischazged to the Rito Seco. The <br />water that was transported to the tailings impoundment was used to irrigate the recently vegetated <br />areas in the impoundment which, of course, enhanced the evaporation process. <br />Question- "How long will the pit water be sent to the tailings facility?" <br />Response - Probably as long as the nano-filtration facility is being used to process the West pit <br />backfill water. It may be necessary to pump the pit water to the tailings impoundttnent during <br />those infrequent times that the nano-Filtration equipment is totally shut down for thtaintenence or <br />for repairs so the[ the water level in the pit can be maintained at the 8580 feet msl elevation. <br />