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<br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />7313 Sherman SI.. Room 215 <br />Denver. CO 80203 <br />303 866-3567 <br />Fn x: 303 832-8106 <br />~~ <br />STAT~F CC~LO~O <br />4 pF'~O(Q <br />He N t9O <br />~,., ..y <br />,'~~ <br />/876 ~ <br />Ray Romer. <br />Governor <br />Michael B. Long, <br />Division Direnor <br />DATE: April 5, 1992 <br />T0: Larry D. Oehler ~ <br />FROM: Jim Pendleton ~-~'~~" <br />RE: Water Quality Monitor' Inadequacies - Battle Mountain Gold Mine <br />ermit No: M-88-112) <br />As a component of acquainting myself with the Battle Mountain Gold (~BMG) mine <br />and tailings area status, I examined the existing permit documents, 'onitoring <br />requirements, and the 1989, 1990 and 1991 annual reports. My preli inary <br />conclusion is that the water quality monitoring evidenced by the ann al <br />reports and the lack of separate data reports appears to be inadequate to <br />satisfy the monitoring commitments contained in the amended permit. <br />As a portion of their adequacy review of the Permit Amendment in 198, BMR was <br />required to prepare and submit a summary of monitoring requirements or the <br />amended permit. Under the subheading "2.2 Disposal Area and EmbankMent <br />System", the monitoring summary states that: <br />"Monitoring of the flow site and quarterly sampling of th~ <br />seepage from the drain system at the base of the tailings will <br />be performed. A plot of the rate of seepage over time will be <br />maintained and compared to the predicted rate. Chemical <br />analysis of the collection pond seepage on a quarterly basis for <br />the parameters identified in Table G.l-2 of the approved permit) <br />will be performed. In addition, the leak detection system of <br />the collection pond will be monitored for any water weekly <br />during initial six month start-up and monthly thereafter." <br />Further, under the subheading "3.0 Reporting Requirements", the monitoring <br />summary states that: <br />"The data collected as part of the tailings monitoring program <br />will be compiled into an annual report for submittal to the <br />MLRD." <br />"Surface and groundwater <br />compiled and evaluated as part <br />As part of the apprcved permit <br />monitoring results will be <br />of the project's annual report. <br />BMR committed to monitoring <br />groundwater in wells adjacent to the heap leach facility on a <br />monthly basis and submitting the results as they became <br />available. This program will be applied to the tailings <br />