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ti, <br />1 <br />t <br />• • III IIIIIIIIIIIII III <br />INTEROFFICE COMMUNICATION <br />April 28, 2000 <br />To: <br />From: <br />Subject: <br />Jim Dillie ~G~G~J~~ _ /7 <br />Harry Posey (~/j~ <br />Review: Battle Mountain, San Luis Project, TR-028 application, M-88-I 12 <br />Upon receipt of two opposition letters generated in response to proposed TR-028, I was asked by <br />Jim Stevens to review both the TR application and the opposition letters. Knowing that the <br />Division plans to meet with the operator in the near future to discuss the condition of proposed <br />TR-028, 1 am treating the TR as an interim submittal, pending the outcome of our meeting. <br />It is my understanding that the Division asked the company to characterize the anticipated <br />groundwater quality that would result from completion of TR-026. On page l of the TR it <br />appears that the Operator was asked to set groundwater standards. Considering thtit neither the <br />operator nor the Division sets such standards, this statement stands out. Though the original <br />directives have not checked, I believe what the Division intended to request was the Operator's <br />estimate of what could be achieved in terms of groundwater quality by completing the <br />requirements and commitments of TR-026. <br />A direct response to the Division's request was not perfectly evident as it was spread out through <br />the TR-028 application. Much of the text of that submittal comprised synopses of prior <br />documents and general references to unspecific parts of prior submittals, but trying to read over <br />any travesties of writing, I believe the request was indeed addressed, albeit breezily and not very <br />clearly. <br />Whether it is too early to predict what "standards" may be achieved, as indicated in the RMC <br />review, is not clear from either the TR or reviews of the TR. Either there is not yet enough data <br />or the existing data have not been assembled in ways adequate to predict ultimate groundwater <br />quality. However, the intended groundwater "standards;' or the groundwater targets, are indeed <br />expressed. <br />Groundwater quality likely will fluctuate locally as mixtures of various proportions of water <br />from sources with different chemical characteristics report to each sampling point end as <br />groundwater chemistry varies seasonally. The composition of each natural groundwater input is <br />relatively well-known, and the target composition of backfill groundwater has been specified and <br />