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<br />Memo to the BMRI File <br />Long-Term Tailings DETOX <br />page 4 <br />(2) Is the presence of the pre-July, 1992 tailings an imminent hazard? <br />As long as the liner effects containment of the BMRI tailings <br />impoundment's contents, the presence of elevated cyanide levels~in the <br />pre-July, 1992 tailings liquids does not represent an imminent azard. <br />Abatement requirement Items (3), (5) and (6> were each develope to <br />assure thorough monitoring of containment and to affect remedia <br />containment and treatment if containment were lost. BMRI has b en <br />completing the required accelerated sampling and additional ass ssments <br />of its ground water monitoring program. No evidence has been o tained to <br />suggest any leakage of contaminants from the tailings impoundme t. As a <br />fail safe, BMRI is required to develop a recovery and remedial reatment <br />plan for implementation in the event of a leak. Therefore, it s the <br />opinion of the Division that the presence of elevated cyanide 1 vels <br />within the tailings impoundment does not represent an imminent azard to <br />the environment or the health and safety of the public. <br />(3) Is the time frame placed upon BMRI's completion of Item (8) appropriate? <br />Item (8) of the abatement requirements requires BMRI to analyze the <br />implication of the having exceeded tailings cyanide levels for he <br />long-term characterization of the tailings embankment. BMRI is directed <br />to analyze the implications of its violation and to revise its <br />reclamation plan, as appropriate. BMRI is required to completelthe <br />investigation, to submit a comprehensive report, and to complet~ any <br />appropriate permit modifications, within 180 days following <br />detoxification of the active tailings. ' <br />In developing abatement requirement Item (8), the Division atte~pted to <br />prioritize the various abatement tasks. Immediate priorities, uch as <br />returning the process plant tailings to compliance with permit tandards <br />and assessing the adequacy of the containment monitoring progra were <br />balanced against longer term less critical tasks. Based upon t e <br />considerations addressed above, the Division assigned a lower- p iority to <br />the important task of reevaluating the implications of the viol tion for <br />the permanent reclamation plan of the tailings impoundment. In <br />consideration of the significant task represented by Item (8), ncluding <br />comment provided by BMRI, it was the Division's judgment that I 0 days <br />was an appropriate time frame for the completion of this task. <br />