1989-12-01_REVISION - M1988112 (3)

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• iii iiiiuiiiiiu iii , November 21, 1989 Office of Mined Land Reclamation Department of Natural Resources c//++ `, ~t 1313 Sherman Street ~ lam. ti+ ~ ~ ~l E L~ Denver, CO 08233-2273 nl~r, 1 1989 Uear Mined Land Reclamation Board Members: MINEt? LANo RECI~46AATION DIVISION l would like to enter a formal protest against the amended San 1_uis Project mining plan (permit xM-88-1 l2) as filed by Battle Mountain Gold Mining Company. 1 am a resident n~i' San Luis who continues to be skeptical of the sincerity of Battle Mountain Gold plan to protect ttte fragile environment crf the Rito Seco and the San Luis area. Exhibit E.1 of the amended plan states ttrat "smaller stockpiles of topsoil may be located along roads and adjacent disturbance areas.' if you carefully view tt~e mining s[te, storing topsoil close to existing or newly constructed Haul roads only increases the chances of loss of topsoil Lo erosion. The soil of the Rito Seco is sandy loam, easily washed away by small amounts of water or blown away by Che wind. if valuable topsoil is to be stored for later rer_lamation use, this method of convenient storage for Battle Mountair- Gold must not be allowed. That soil must be stored in a protected location. On page E-4, Battle Mountain Gold states that 'an engineered spillway' will discharge storm water flow into 'the existing natural arroyo." The term 'arroyo' refers to a 'water carved gully' as defined by Webester's dictionary. By spilling the water flow from the tailings area into this existing arroyo, Battle Mountain Gold will increase the erosion of the area. the channeling of the water into a spillway will also increase the amount of flow released into the arroyo, cacrsing much greater volumes of water to rush down the mountain. I think this increases the chances of flood damage to the mountain ecology, as well a being a threat to the town of San Luis duriny major rainstorm, if the tailings pond was ever compromised sod a major spill would occur, all waters would rush directly into San Luis. No additional containment strc[ctcrres gave been engineered. Battle Mountain Gold has admitted that some