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~ iii iiiiiiiiiiiu iii • <br />STATE OF <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmem of Nawral Resources <br />1317 Sherman SL, Room 215 <br />Denver, Colorado 80207 <br />Phone: 1703) 866-1567 <br />FA%: (3031832 8106 <br />November 28, 1995 <br />Ms. Sally Hayes <br />Battle Mountain Resources, Inc. <br />P.O. Box 310 <br />San Luis, CO 81152-0310 <br />RE: Tailings Impoundment Reclamation Evaluation, San Luis Project, <br />Permit No. M-88-112 <br />Dear Ms. Hayes: <br />~I~~~ <br />DEPARTMENT' OF <br />NATURAL <br />RESOURCES <br />Ruy Romer <br />Governo. <br />lames 5. LochheaA <br />E*eculive Direcmr <br />Michael B Long <br />Dmis~on Duec~or <br />I finally had the opportunity to complete a cursory review of the Reclamati n Evaluation <br />report that BMRI submitted to the Division in response to concerns that th chemical <br />constituents of the tailings material, that was deposited in the tailings imp undment <br />during 1991 and 1992, was different than originally characterized in the a proved <br />permit. <br />In addition, I reviewed all the correspondence, notes, and documents that I have on file. <br />From the information I have, it appears this issue has never been resolved. Because this <br />item is part of the abatement of the 1992 NOV I think we should re-initiate the review <br />process so we can come ever closer to abating the NOV. <br />I would like to begin by presenting my interpretation of the sequence of e~yents and <br />detailing the documents I have on file. If my interpretation is incorrect, orlmy file is <br />incomplete, I would like you to fill in what I am missing if possible. <br />In 1992, BMRI was issued NOV M-92-026 for exceeding permit cyanide s andards in the <br />tailings impoundment and the collection pond. The Board ordered BMRI o complete <br />several corrective actions; one of which was Abatement Requirement No. This <br />corrective action required BMRI to reevaluate the tailings chemical constit envy in order <br />to determine whether the excursion from permit cyanide standards had res. Ited in a <br />change in the tailings character. <br />The history of tailing deposition within the impoundment is well known. rlefly <br />summarized, AVR-treated material was deposited in the upper and lower onds from <br />April 1991 through April 1992. CYTOX treated tails were deposited in th@ lower pond <br />from April 1992 to June 1992. BMRI treated the tailings with hydrogen peroxide from <br />