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iii iiiiiiiiiiiu iii ~ <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1 ] 13 Sherman St., Room 215 <br />Denver, CO 80203 <br />Phone: 1703) 866-3567 <br />FA%:1]031 832-81 06 <br />MEMORANDUM <br />DATE <br />TO: <br />FROM <br />RE: <br />June 9, 1993 <br />Ken Salazar, Ron Cattany <br />oe cow <br />~t`P4 <br />N~~ <b <br />0 <br />••~ <br />Roy Romer <br />~M1 Governor <br />Michael B. Long <br />Division Direr mr <br />Mike Long <br />Battle Mountain and Platoro; Costilla and Conejos Counties <br />Following up on our conversation yesterday concerning a CDH memo to <br />Conejos County we contacted Pat Nelson at WQCD trying to track it down. <br />Pat does not recall a memo to Conejos County, but did furnish for us an <br />internal memo about Conejos County. A copy is attached. <br />Regarding the CDH interoffice memo, I feel that the information about <br />Battle Mountain is correct but harsher than warranted. Battle Mountain <br />is in compliance in virtually every way. The complaints mentioned are <br />coming from relatively uninformed and biased citizens, and the runoff <br />problems to which they refer are coming mostly from the. county road <br />right of way. As far as CDH's hands being tied on the project, I do <br />not know why they would refer to the situation in this wad. They have <br />no jurisdiction. The facility is a zero discharge facility, and so far <br />under extensive sampling we have found no evidence of a discharge. <br />Therefore, an NPDES permit is not required. <br />Regarding the Cedar/Union operation at Platoro, please recall that this <br />is a prospect and therefore all of our records are confidential. (CDH <br />would not be held to any confidentiality except for infonnation gained <br />from DMG records.) The information in the CDH memo is. essentially <br />correct. However, there needs to be made a distinction between water <br />in the toe-drain sump and the water in the Conejos River. During high <br />flow, groundwater that exits from the toedrain sump flows into the <br />Conejos River. Our sampling in January indicated high arsenic in the <br />toe drain sump, as predicted, but no detectable arsenic in the Conejos. <br />As a result of DMG's inspection in January, which was conducted from <br />snowmobiles, the company re-opened the Conejos River woad and re- <br />started their water treatment plant in mid-winter. CDH was asked to <br />join in the inspection, but declined. <br />On both of these operations, DMG has been more active in t;ze field than <br />CDH. At Battle Mountain we have been inspecting almost bi-monthly <br />since April of 1992. In addition, under Board Order, we eve conducting <br />independent third-party monitoring. At Platoro we conducted three <br />inspections in the latter half of last year, and :B snowmobile <br />inspection in January. It was at DMG's initiation that the company <br />moved back on s to as early this year as they did. We concur that the <br />company is having trouble with their water treatment plant, and that <br />needs to be corrected. <br />