Laserfiche WebLink
llnncttc Quill <br />Dave ~lkc:s <br />]title 12, Z~;O(i <br />Page 3 <br />indicates lnat BM's failure to address /;coon/; •~,ttcr discl;arga and the associated plume 5T1U- by i3rl <br />have rosul'.ed in continued water quality viulc:iuns downgradicnt of the Bbi proporty. ' P~PeRx~~`C <br />3. 'there was Ample Dula on the Ttecord to Tndicnte this b'iolation Would Occur <br />The discharges from the West Pit should h.r :come as a surprise to no one. Concerns <br />regarding discharges form the pit were pres~a;cd by local cnizens a decade ago. See <br />ultachcd /conscript of public hearing before ~11,RH, January 2~, 1990 (attached). In fact, <br />these concerns were substantial nnouglt that 3~,4's NLRB permit included provisions tn_ ts~ t ~ ~~t,r.. <br />prevent such a discharge by requiring a slum;: wall. !d. at u. 266. Nevcrthcless, BM did Sru~`t t~ <br />not instal] this prevenlntive mc.nsurc. BA•1 and stag agCll~ aware that dc•watcring ~%4t's ~S _ <br />of the pit would be accessary because of itt-Bowing water, and they also kt w tF~at the 6~ ~ <br />lowest pc;mcability fonnatiun with contact ro the pi[ was tha alluvium.. N~ethcaess, "`'~ <br />FS6T Tr"~ <br />T3M's consulting cnginncrs and the ittvolvcd state agencies ovcrloukeJ the fats that the .,q~ ~ <br />water which flowed into the pit «'ould flow out via the path of Icast resistance, entering TtJ ~ ~~ ~i <br />thr: alluvium and mixing with waters of the U.S. ~~.F. ~~, <br />PurL•ltcmture, the gcochemical reactions which have dcgracied wafer qualify wen: <br />prcdictcd by gcocltettric;tltclls concltleteil by H~1 in the original permit and in TR• I8. ~ <br />Technical memoranda provided by HM's consultants support this fact. See, e.g., BM's <br />Proposed Wurkplan of June S, 1999, which states that pilot testing of microbiological <br />water aeatment (leaching tests on columns of waste rock) "released large quantifies of <br />manganese." (p. 3,!~ 1), Nov., 1998 TR-l5 Response Plan: Supplcmcntal Moeitrn•ing at <br />West Pit, BMRI's Snn Luis Project, section 3.3, p. 14: "Ttt a memo from Geochi.nica to <br />Ilatry Posey of the 1)ivisiort in 1995 discussing TR-] S, Geocltimica preclietecl the <br />potential for some flushing of sulfate, although the exact levels were not provided," Thc <br />discharge of groundwater contaminated with various pollutants (manganese, sulfates, <br />etc.) is repeatedly prcdictcd in 13MRI's technical memos and documents well, well <br />bcforo BMRi applied for a permit. See Appendix A to TR-18, Analytical Rcpor 880336, <br />8/15/88; .See also App. B, Technical Memorandum T 1l16/9S, BMR! lac. San Lttis Minc <br />to Mark T.ogsdott, Geochirttiea. See also, 10/18/95 Technical Memorandum to .Jim Dillie <br />and I)t'. Tiarry Posey, DMG from Mark J. Logsdon; See also, 02/01/96 Technical <br />Mcntorandum to ]im Dillie and Dc Many Posey, DMG from Mark I. Logsdon; See also <br />8/IZ/9G Mcnto to Jim Dillie firottt I•Iarty Posey; See also Tccltnical btentorandum by Jim <br />Pinky, Sitcpard Miller to BMR detcd January 25, 2000. The ;~11.IZH and HM slrould <br />have expected these problems as the local groups dic1. <br />r u~m.ani eem•m Nu• e. dad namaa+N <br />