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1 • III IIIIIIIIIIIII III • <br />12975 W. 24th PI. <br />Golden, (Applewood) Colorado, 80401 <br />(303)237-8865 <br /> <br />August 2, 1993 <br />AUG 5 ]993 <br />r r, ~~ ~. <br />~ ~ ,C ~ti. <br />~ ', <br />DiVISICn 01 A4it7(;i 3._ . <br />~- ,,yy. n <br />Mr. James C. Stevens ~~ <br />Senior Reclamation Specialist ,'I" <br />Division of Minerals and Geology ,1(U'~ <br />1313 Sherman Street, Room 215 rf~L( <br />Denver, Colorado 8D203 <br />RE: Review of Battle Mountain Gold Stipulations to TR-OS <br />Dear Mr. Stevens: <br />As you may recall, we are assisting the Costilla County <br />Conservancy District in reviewing groundwater related information <br />on the Battle Mountain Gold mine at San Luis. Recently, I received <br />a copy of a letter dated July 12 from your office to Mr. Andre <br />Douchane of Battle Mountain Gold. This letter addresses <br />stipulations to TR-08. We have some concern with the modification <br />to the first stipulation as presented in your letter and have <br />prepared this letter to present those concerns. <br />The modified stipulation states that BMG will monitor until <br />two conditions are met. The first condition is that th@ flow from <br />the tailings facility has ceased for a period of 1 year. The <br />second condition is the "groundwater below the tailings facility <br />and collection pond is of such quality that no remediatilon efforts <br />are required." We concur in principle with these conditions, but <br />are unclear of the circumstances under which your office would <br />declare the groundwater to be clean. We do not believe that simply <br />testing the existing monitor wells one year after the pond flow <br />ceases is adequate to conclude that there is no contamination plume <br />under the tailings. It is unclear if this is the intent of the <br />Division, or if alternative means of assessing contamination is <br />anticipated. <br />We believe that this determination is best made on the basis <br />of direct evidence, such as monitor wells constructed through the <br />presumably dry tailings into the underlying vadose zone and <br />groundwater. Such monitor wells should be constructed in a manner <br />to prevent contamination from migrating down into the acjuifer, and <br />properly sealed upon completion of testing. In lieu of such <br />evidence, if the existing monitor wells are to be used, we believe <br />that some minimum period of time should be established after the <br />Ground Water Hydrology Engineering Geology Geophysics Geotechnical Consultants <br />