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t <br />~~~~~~~~~~~ ~-~~-t~CI~.~l~~~ <br />' ADEQUACY RESPONSES TO COLORADO MINED LANq UN L 2 1992 <br />RECLAMATION DIVISION ADEQUACY COMMENT'S TO Mined Land <br />' TECHNICAL REVISION NO. 6 - Rerlam~+~,,.. n• '"ran <br />' QUALITY ASSURANCE/QUALITY CONTROL PRO'T'OCOLS <br />FOR THE COLLECTION OF SURFACE AND GROUND WATER QUALITY DATA <br />SAN LUIS GOLD PROJECT, COSTII.LA COUNTY, COLORADO <br />' COMMENTS BY HARRY POSEY <br />1 1. There needs to 6e a sampling point ort dre Rito Seco downstremn of dte tailings <br />impoundmetn. The present RS-5 point is in a dry alluvial valley and yields no <br />water. 77te proposed sampling point would need to he nut9ide the permit <br />1 boundary. l recontntend a point just downstream of where the light duly road <br />crosses -he stream, as shown on Figure 1 in dte Protocol Proposal. <br />' RESPONSE: Station RS-5 is not located in a "dry alluvial valley"; it is on a perennial reach <br />of Rito Seco and has been monitored on a quarterly basis since the pre-mining <br />period. BMR believes that Comment No. I is actually referring to Station RS-6, <br />' which is located downslrearn of the tailings facility in a sub-basin gributary to Rito <br />Seco. This sub-basin is generally dry. We do not believe an additional <br />monitoring point on Rito Seco is warranted at this time, and the location proposed <br />downstream of where the light duty road crosses the stream is in a reach of <br />Rito Seco that is not perennial, as the Salazar Ditch, at times of the year, diverts <br />all of the flow in Rito Seco. Additionally, it has been previously established that <br />the dry reach below the tailings facility does not Flow into the Rilo Seco but, <br />rather, flows south when it exits the canyon and flows to Culebra Creek. <br />' Therefore, the proposed location is not downgradient off the tailings <br />impoundment. <br />' 2. Ahhough many monitor wells have been installed, only three rowihely yield water <br />enough for sampling: M-4 and M-]0 o+t the Rito Seco, and Ap-9 west of the <br />tailings impoundment area. Aldtough M-9 is apparently downgradient of the <br />tailings ponds, M-4 and M-10 are also down gradient of the tailings. W/terlter <br />a leak from the tailings would flow toward the north (toward M-4 and M-10J, or <br />whether it would Jlow toward the west (coward M-9J, or whelhcr it would flow in <br />other directions cannot be determined either from the permit or from the <br />Monitorit:g Protocol Proposal. <br />The April 1992 NOV Abatement Plan calls far sampling M-2, M-6, M-7, M-8 mtd <br />M-9. However, because M-2, 6, 7 and 8 are dry, and because rve do not know <br />' -1- <br />i <br />1 <br />