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• III IIIIIIIIIIIIIIII MINED LAND RECLAMATION DIVISION Department of Natural Resources 1313 Sherman St., Room 215 Denver. ~O 80203 303 866-3567 RA x. 303 832-8106 STAT~OF Chi Lfl~~O --~--- `~_~< .\2,~~i ~ /876 ~ ` Roy Romer, Governor Michael B. Long, Division Director DATE: April 24, 1992 T0: Mike Long FROM: Harry Posey ,11~ RE: Review of A. Douchane's April 16, 1992 Response to Jim Pen leton's April 7, 1992 Letter; Battle Mountain Resources; San Luis roject; M-88-112 [Draft Letter Sent To long and Humphries, April 2 1992] At your request I reviewed Mr. Douchane's letter and its supporting material. As my response to Mr. Douchane's package depends on my own assessment f the situation at San Luis, I will include several site observations that pertain o that package. GENERAL COMMENTS Although I think BMG is responding quickly and with due regard to t e Permit Revision and its Stipulations, parts of their investigation still h ve shortcomings. These include (1) the sampling program, and (2) adeq acy of the leak detection, monitor well, and monitor well systems to adequately det ct off-site contamination. Sampling and Analysis Currently, BMG has an "in-house" probe measurement technique wfpich they use to detect free-cyanide. Probe results indicate that free-cyanide levels in all three ponds are generally below 25 ppm, and are leveling off o~ decreasing slightly with time. However, you will recall that Gary Dodson told you and me that independent analyses from BMG's outside lab CAccu-Labs Re earth Inc.) run between 60 and70 ppm for the same samples. BMG is currently conducting a quasi "Round-Robin" in which they are comparing sample Splits in two independent labs with their in-house lab. These results Should be available this week, and will tell whether their in-Douse technique is adequate for monitoring. We have a few Colorado Department of Health samples taken April 1 and April 3 that give free cyanide levels of 240 in the slurry, 130 in the upper tailings pond, 79 in the lower tailings pond, 90 in the collection pond and 100 in the leak detection system. These fall in the general range of Acc -labs samples that were collected at the same time b_v BMG. However, we do n t have corroborative samples from the 6MG lab as they did not begin r utine in-house sampling until P.pr•il 8, the day the mill ~das re-started. Suffice to sav. '~z .~ nc* '<no:~ the current levels of cyanide of any species in any of the p^r~- •_ "~z 'e_!: detact 'en ;v;tem- Samples that I collected on April 16. '~':' - '- .-~~ -a: :;_ ~__mpiete by sometime thi~ wee<.