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~. ' 2. Mobilization and implementation of a interim active water treatment system to treat water collected and pumped from the seepage front (i.e., contained surface seepage ' expressions), the flow of groundwater from the West Pit to the Rito Seco alluvial aquifer (i.e., Wells M-18, -19, -20, -28, -29), and backfill wells (BF-3, -4, or -5) ' 3. Submittal of a Minimal Dischazge Industrial Wastewater Permit application to the CDPHE and subsequent agency approval of this application to operate a interim action active water treatment system described previously (submitted August 30, 1999) 4. Construction of a slurry wall to minimize the flow of Rito Seco alluvial groundwater ' into the West Pit (on the east side of the West Pit) and to control the oinflow of West Pit groundwater into the Rito Seco alluvial aquifer (on the eastern and southeastern ' side of the West Pit) 5. Implement the performance monitoring plan that was prepazed and submitted under sepazate cover to satisfy Item 4 of Cease and Desist Order (Submitted September 10, ' 1999). These response actions are designed to: • stop the flow of groundwater from the backfill of the West Pit into the Rito Seco ' alluvial aquifer • control the contribution of West Pit groundwater from the backfill .it the surface ' expression of the seepage front • establish the hydrologic conditions that were anticipated in CDM(i TR-18 and substantiated in TR-26 • provide the necessary management and treatment of excess flows as r:quired based ' on the water quality and applicable regulations • provide a physical barrier to control the flow of groundwater from the Rito Seco ' alluvial aquifer to the West Pit (east side of the West Pit) • provide a physical barrier to control the flow of groundwater from the West Pit to the t Rito Seco alluvial groundwater system. This response program consists of three phases. The initial phase consists of interim active water ' treatment (under a CDPHE Minimal Dischazge Industrial Wastewater Permit) using the interim water treatment facility that has been constructed at the site. Interim water treatment will last ' approximately 3 to 4 months. BMRI also proposed the construction of a slurry wall along the ' eastern and southeastern boundary of the West Pit to provide a physical barrier to t1e movement Ba(tle Mowtain Resources, lnc. Shepherd h1i1(er, lnc. ' uq,.wn~y.rMiroo:e;wp+.r~doimr~,r,iapk 2,p~.+<p~m~...+ial,~ 2 September l7, (999