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<br />Mrs. Marek <br />-2- <br />May 6, 1988 <br />immediately, if desired, without waiting for approval of the proposed <br />technical revision. As a practical consideration, Phase 1 does not involve <br />the use of chemical treatment, is essentially the same treatment system as <br />previously approved by the Division for use on an emergency basis, and should <br />have limited environmental impact. WFC estimated they might want to begin the <br />Phase 1 demonstration during the week of May 9, 1988. <br />So far as the time frame anticipated for review, approval and completion of <br />the Phase 1 and Phase 2 demonstrations, receipt of a complete and adequate <br />proposal by May 12, 1988 could result in final approval as early as the second <br />or third week of June ie. 30 to 40 days later. If this occurs, Phase 2 could <br />be completed by mid to late July. If problems were encountered in approving <br />the revision, but approval could be given within the maximum 70 day period <br />allowed by CMLRD rules, the start of Phase 2 might be delayed until late July <br />and completion until late August. Certainly the Division does not want and <br />will try to prevent each additional delay from occurring. There is, however, <br />no way to assure this not happening. <br />It was also agreed, in order to expedite the implementation of whatever mine <br />water treament system the demonstration proved to be effective, that WFC would <br />also resubmit the technical revision proposing the construction of Ponds 5 and <br />6 to serve as part of a permanent, passive (non-chemical) treatment facility. <br />Submittal of this by June 1, 1988 would also satisfy Step 2 of the required <br />abatement of CMLRD Cessation Order No. C-88-017. Approval of this revision, <br />however, involves WFC satisfying the relatively extensive requirements of <br />CMLRD Rules covering disturbance of the alluvial valley floor (AVF) in which <br />the ponds are to be built. It should be understood that submittal of a <br />technical revision to the permit fully describing the treatment system for the <br />Golden Eagle Mine water is required by the Division for abatement of the <br />cessation order. The system proposed by WFC and its physical location, <br />however, are at WFC's discretion. A decision on the anticipated revision, <br />because of the AVF concerns, might require anywhere from 30 to 70 days or more <br />from receipt of the complete and adequate proposal. <br />Based on the above, approval for the construction of Ponds 5 and 6, by <br />themselves, might be had and their construction begun as early as the first <br />week in July. Testing of their effectiveness, regarded by WFC as Phase 3 of <br />the mine water treatment demonstration, might then begin in mid July and <br />extend to early August. If CMLRD approval is delayed until the maximum <br />permitted 70 days has elapsed, construction and testing of the system would be <br />set back an additional 30 or so days and not completed until early September. <br />If Phase 1 of the demonstration does not show the mine to be able to meet <br />effluent limits by passive (non-chemical) means or if the passive system with <br />Ponds 5 and 6 does not prove to function adequately in the Phase 3 <br />demonstration, further revision of the mine permit will, of course, be <br />required in order for the mine to use, on a permanent basis, a chemical water <br />treatment system. Since such system would presumably already have been <br />reviewed, approved, and, hopefully, "demonstrated" by this time, further <br />revision (or revisions) should be regarded as minor and approvals could be <br />secured in a matter of ten days time. <br />