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<br />Memo to Steve Shuey 4 June 15. 1998 <br />and there will be no adit discharge." In response to problems cited in Division inspection reports for <br />the Bulldog Mine from 1982 and 1983, Homestake reiterated "Mine drainage from the portals will <br />cease once pumping operations are curtailed." <br />2. In the Division's 4-12-89 inspection report for the Bulldog Mine it is stated "Water Treatment <br />Facility: The mine is not being pumped, so this facility is inactive. It is not anticipated that the water <br />level will rise to the entry level." In the Division's 6-8-92 inspection report for the Bulldog Mine it is <br />stated "Inspected both Bulldog Mine Portals - no water dischazge hence the water treatment plant does <br />not need to be run during temporary cessation." <br />Analysis of items 1 and 2: It is clear from review of the file up to 6-8-92 that it was believed by both <br />the Operator and the Division that the location of the regional water table well below the elevation of <br />the Bulldog mine portals would prevent any discharge from the portals once mine pumping ceased. <br />3. In the Division's 12-1-92 inspection report for the Bulldog Mine it is stated "The mine opening <br />on the 93601evel must be sealed. Homestake should submit design details for the closure for Division <br />review prior to construction. A hydraulic seal for an azea of inflow deeper within the adit was <br />discussed on site. Please also submit design details for this seal." Homestake's annual reclamation <br />report dated 10-20-93 states "The 93601evel portal was sealed." <br />Analysis of item 3: December 1992 was the first time the Division was advised that there were inflows <br />to the 9360 adit that may require management to prevent adit dischazge. The Division directed <br />Homestake to submit design details for any hydraulic seal prior to construction. Homestake then <br />proceeded to seal the adit, and to install an interior hydraulic seal without following the Division's <br />direction to submit the designs for review. <br />4. The Division received from Homestake, by a letter and attachments dated July 19, 1996, a <br />description of seepage that had occurred from the backfilled 9360 portal during 1995. This was the <br />first indication in the history of the Division's Bulldog file that an adit discharge occurred that was <br />unrelated to pumping of the mine. Via this same communication, the Division was informed for the <br />first time that Homestake had installed a hydraulic seal at a location approximately 150 feet in from the <br />9360 portal. <br />5. On 8-13-97 the Division received a copy of a letter from Homestake to the Water Quality <br />Control Division dated 7-31-97 stating that 9360 adit dischazge in 1997 had peaked at 60 gpm and then <br />had dropped of to approximately 30 gpm by the end of July. This was the Division's first notification <br />of the magnitude of the 9360 adit flows which had previously been characterized by Homestake as "a <br />temporary moist seepage area along the outer margins of the surface soil cover at the portal entry for a <br />short period of time during the Spring runoff season" (letter dated 7-18-96 from Homestake to Bureau <br />of Land Management), and "a seasonal minor seepage occurrence at the closed adit which is evident <br />for a short period of time during Spring melt" (letter dated 7-19-96 from Homestake to the Division). <br />6. It is stated in the Division's meeting notes from a 10-23-97 meeting with Homestake that "If <br />