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<br />-z- <br />completion of backfilling in Pit No. 2 directly across from the office <br />building and along the base of the reclaimed spoils in Eckman Park. It <br />follows that if future mining is permitted along the same dip slope to the <br />southwest (i.e. Little Middle Creek Tract), similar post reclamation <br />hydrologic conditions will result. The technical literature indicates that <br />increased TDS levels resulting from spoil leaching is a long term condition. <br />In March, 1985, measured flows ranged from 60 gpm to over 1,000 gpm. TDS <br />concentration for three samples ranged from 3,400 mg/1 to 4,150 mg/1. In <br />light of the dramatically increased flow rate, the worst case PHC scenario and <br />any downstream water quality modeling may need to be revised. To date, we <br />have not required CYCC to monitor and submit spoil spring data to the <br />Division. Given the apparent potential for material damage and the <br />ramifications with regard to future permitting decisions, it is my feeling <br />that monthly monitoring of flow and field parameters and quarterly complete <br />analyses should be required. <br />I talked to John Kubic at the Health Department regarding the issue of spoil <br />discharge in general and CYCC Pond F spring in particular. He indicated that <br />the discharge was in excess of state salinity regulations, but that the <br />regulations were essentially meaningless due to the high cost of <br />desalinization. A company has only to demonstrate that treatment would be <br />economically prohibitive in order to obtain a variance from the salinity <br />regulations. <br />Mr. Kubic indicated that the Health Department was also concerned with heavy <br />metals concentration of the discharge, and had more stringent standards which <br />could be applied. Evidently, Health is considering the possibility of <br />enforcement and required mitigative measures due to the metals concentrations. <br />DM/mis <br />1783E <br />