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• Df~AFT <br />Minutes, July 22-24, 1992 Subject To Board Approval 1 <br />In response to Ms. Jacque z' comments, Staff explained the process that <br />the Division uses when conducting inspections and completing reports. <br />Staff said that each inspection is not a full or comprehensive <br />inspection of the entire mine site, however, any violations noted <br />during the time of an inspection are documented in the report. Staff <br />said it is the Division's opinion that the inspection frequency for <br />this site is adequate at this time. Staff said the Division would <br />begin Sending copies of the inspection reports to the Costilla County <br />Clerk. <br />In response to a concern raised by Frank Johnson regarding the County <br />Clerk's ability to make the inspection reports available for public <br />review, Ms. Jacquez stated that the County Assessor had agreed to <br />establish a system for filing these documents and making thE~m available <br />to the public. _ <br />Staff discussed the issues addressed by the objectors. Staff said that <br />several of the comments relate to TR-10 and stated that issues raised <br />in that regard are being addressed in the operator's responses to the <br />Division's adequacy concerns. Regarding independent monitoring, <br />specifically whether this should include a point at the Rito Seco <br />Creek, Staff said this determination will be made based on the results <br />of the additional ground water analysis being conducted on the area <br />beneath the tailings embankment. <br />In reference to the issue of tailings relocation, Staff said the <br />tailings structure ("dam"> has been deemed structurally stable and is <br />collecting and dewatering tailings slime deposits. Staff said that at <br />this time the Division does not have a concern in regard to the <br />tailings structure, because there has not been a problem from loss of <br />containment or contamination. However, Staff said it may take years <br />for the tailings to dewater to the point that final reclamation can <br />occur. The disposition of the tailings structure will to addressed <br />additionally in the final response to abatement requirement No. 8, <br />reassessment of the reclamation plan. Staff answered questions from <br />the Board. <br />The Board said there are 3 outstanding issues requiring resolution: <br />1) technical issues related to how monitoring will be conducted--Staff <br />said this will be addressed during a review and approval of TR-10, <br />2) independent monitoring program--this should be in place as soon as <br />agreements are reached by all parties and 3) establishmert of a date <br />for meeting full compliance with all permit conditions. In response to <br />an inquiry from the Board, Staff said that although the Division is <br />satisfied with requiring the operator to achieve compliance as soon as <br />possible, setting a date for compliance by the November 1992 Board <br />Meeting would be feasible. <br />The Board requested that the Division, during the August 1492 Board <br />Meeting, provide a recommendation for a deadline by which the operator <br />must be in full compliance. The Board also asked that the Division, <br />when determining a deadline date, consider the fact that problems Could <br />occur at the site and allow enough time for potential problems to be <br />resolved prior to the onset of freezing weather conditions. <br />