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~= •-~ III IIIIIIIIIIIIIIII` M ~ <br />STATE O~ COLORADO <br />MINED LAND RECLAMATION DIVISION of ~a~ <br />'c _ q <br />Department of Natural Resouroes Q ~.,.+ <br />~'~ ~g <br />t313 Sherman St., Room 215 {~r~o ~ <br />Denver. C080203 ~, ~,~""„ -.fir <br />303 866-3567 'rate' <br />rnx:303 832-8106 <br />Roy Romer, <br />Gavemor <br />Michael B Long, <br />Division Director <br />DATE: April 5, 1992 <br />T0: Larry D. Oehler <br />~-~ <br />FROM: Jim Pendleton ~ ~`~ <br />RE: Water Qual'ty Monitor' Inadequacies - Battle Mountain Gold Mine <br />Permit 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, monitoring <br />requirements, and the 1989, 1990 and 1991 annual reports. My preliminary <br />conclusion is that the water quality monitoring evidenced by the annual <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 1989, BMR was <br />required to prepare and submit a summary of monitoring requirements for 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 the <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.1-2 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 monitoring results will be <br />compiled and evaluated as part of the project's annual report. <br />As part of the approved permit 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 />