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Larry Oehler November 11, 1993 Page 4 Corrective action item 2 states: "A spill of process water occurred outside of the lined containment facility October 1, 1993 as a result of failure to take proper precautions. Implement your permit approved spill response plsn. Submit a report on the spill and your response. Include measures that will be taken to prevent this type of spill from happening in the future." Section 9.3 of the approved Emergency Response Plan states: "Small incidental controllable spills that do not pos=_ a human health or environmental hazard shall be remedie9 immediately by trained mine personnel." As the Division witnessed, response to the overflow situation was immediate. Also, in accordance with the Emergency Response Plan, BMRI submitted a letter dated October 12, 1993 to the Division fully explaining the circumstances of the overflow event, the response, the water analysis report, and the pre- cautions taken against similar situations in the future. BMRI submitted a second letter dated October 26, 1993 to the Division with additional analytical reports on soil s,smples. As you know the reclaim water system is equipped with a primary, secondary, and tertiary containment design a;~ set forth in the approved permit. At no time did the ove:-flow water (a mix of fresh water and detoxified, reclaim wester) exit the tertiary containment for the mill area. The final analysis report for the water sample collected from tl~e ponded water in the mill area showed cyanide concentr,~tions to be below groundwater and drinking water standards ,st 0.16 ppm CN-wad and 0.16 ppm CN-total. Corrective action item 3 states: "Spacing of drain pipes in the Phase II liner construction area was over the 40' specification. In your submittal for problem 1 above demonstrat~a that the observed 40'-60' pipe spacings will be adequate for the drainage blanket layer to drain the facility as approved in your permit." The Division rough estimated the spacing of underdrai~i pipes which were not completely installed. Amore appropriate method of checking underdrain pipe spacing would be t~~ observe the actual placement and installation of the underdrain pipes during liner cover activities. With the employment of the third party engineering oversight, 1:he actual methodology of underdrain pipe installation wi.Ll be inspected.