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NOV- x,95 MON 6:36 PM TESS~CT PRODUCTIONS FAX N0, 3479713 P. 4 <br />3 <br />DISCUSSION <br />Overall, the previous Operator pattern of partial, tardy compliance with requirements appears <br />to be still intact. Of paimary concern is the fact that, as of this date, available pond freeboazd is <br />minimal, and the mazgin.between the water level at the top of the decant standpipe and the level at first <br />water contact wilt soil at the dam face is nil to negative. <br />We are gratified, of course, to sce the removal of junk from the millsiiu and the rehabilitation <br />of the diversion ditches, site harming, and storm-water pondiag. But this does nothing to relieve our <br />major concern; that of a repetition of the illegal discharge of process ware and entrained tailings solids <br />to Cash Gulch that occurred this Spring. We fully share Division Staffs concerns regazding overall <br />site water balance - we raised those concerns quiu some time ago as you know, and we are deeply <br />distressed to see how the available consnncdon/repair time has been squandered. Weather here is <br />drteriorating rapidly with the onset of winter. Temperatures are falling, together with achievable <br />e•+aporation rates. Significant snowfall could occur at any time, malting further work on the pond liner <br />foot more difficult (and expensive), thus encouraginE yet further delays. <br />In sum, we are rapidly being forced into a position where we must choose between direct pond <br />w;aur contact with a raised dam crest of tmlmown and questionable integrity and uapermitted discharge <br />o~F Hazel-A effluent to Cash Gulch. <br />It is worth noting the following: <br />o On February 28, 1995, a Notice of Violation and Cease and Desist Order was issual <br />by the Boazd which stated, at Ium 1, 'Cease and Desist on the use of the mill and <br />tailings impoundment until a properly engineered plan is submitted to the Division in <br />the form of a new permit applicatioa which solves the problems of a lack of e <br />free~8_ra 'n he 'mnoun meat, the instability of the currently deposited tailings near the <br />embankment, and the cleanup of the tailings in the building" (Emphasis added.) . <br />o The DMG Staff Inspection Report dated June 7, 1995 stated in part, "... (T)he Division <br />will not approve the new Gold Hill Mill application ... until a viable water management <br />plan is reviewed and approved. !l.~111 ews in the Loer muct be repaired lZy~~y 1_ <br />>~° (Emphasis added.) <br />o The DMG response letter to COME dated June 9, 1995 states at item 6, "... It is the <br />Division's view that the water behind the Hazel-A bulkhead is process water .... It is <br />the Division's iatemion to require permit conditions that will assure that the Gold Hill <br />Mill is azero-discharge facility, as that any process water releases are properly <br />permitted." And, at item 8, "...(Al t bu P,~ini is +++o ~nrc of iling~ would )LVe <br />~n hP rtnane~ out of Le ASP -A a it and reunited tO rite ~A1 a ... 1aS an ongoing <br />maintenance task." (Emphasis added.) , <br />