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12/10/98 THU 18:14 F.a,S • III IIIIIIIVIIIIIIfI • <br />WESTERN 11~INING ACTION PROJECT <br />1405 Arapahoe Ave. <br />Boulder, CO 80302 <br />(303) 473-9618 <br />Fax (303)440-8052 <br />wmap@igc.org <br />Via Fax - Hazdcopy to Follow By Mail <br />December 10, 1998 <br />Colorado Mined Land Reclamation Board <br />Cfo Mr. Michael Long, Drrector <br />Colorado Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Re: Battle Mountain Resources Inc., San Luis ProjeM, M-88-112 <br />Dear Mike: <br />This letter is submitted on behalf of the Peoples Alternative Energy Servi es (PASS), by <br />and through its undersigned attorney, and regards recent and ongoing concerns th BMRI's San <br />Luis Project (Mine). PAES has been actively involved with issues at the Mine f ,over ten years <br />and has participated in numerous DMG and MLRB hearings and discussions singe 1988. <br />It has come to our attention that the DMG and MLRB are currently revie~g various <br />options for dealing with the permit violations and othtt concerns stemming from a Mine's <br />exceedences of water quality protective levels. This letter details otu concerns w~th BMRI's <br />proposed approach and DMG/MLRB response. We have reviewed recent water diuality and other <br />information as best as can be done on short notice and reserve the right to submit additional <br />comments as the situation develops and more information comes to light. <br />f~ 006 <br />Overall, it appears that a serious water quality problem may be developin at the site. At a <br />minimum, surface and ground water standards aze being violated as a direct resul~ of the Mine's <br />activities and its alterations of the hydrologic regime in the area. We respectfullyrequest that the <br />DMG and MLRB take specific actions to ensure that all statutory and regulatory sponsibilities <br />are met and that BMRI is held fully accountable for its actions. Based on our review to date, our <br />specific concerns follow. <br />I. Surface and Ground Water Quality le Not Being Protected <br />The data and analysis submitted by BMRI acknowledges that surface and ound water <br />standards are not being met at the site. Specifically, ground water protective leve~s set in the <br />