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Memo to Steve Shuev 5 June 15. 1998 Homestake wants long-term approval of infiltration, water quality issues would have to be addressed rigorously. a. Chazacterization of subsurface flow paths of infiltrated water. b. Quality of infiltrated water vs. ambient ground water quality." 7. It is stated in an internal Division memo dated I 1-7-97 that "A component of the investigation of the sources and quality of the 9360 adit dischazge must be a characterization of ambient ground water quality." Analysis of items 4, 5, 6 and 7: The Division was not apprised of the potential for dischazge from the 9360 adit until 1996 and was not apprised of the magnitude of the dischazge until 1997. Since that time, the Division has been consistent in its position that forced infiltration to ground water of the 9360 adit water not create an unacceptable ground water or surface water quality impact, and that under Rule 3.1.7 and the Interim Narrative Standazd for ground water chazacterization of ambient ground water quality is necessary unless an Operator chooses to submit to the Basic Standards. Analysis of items 1 through 7: During the July 1995 Bulldog Mine hearings, the Mined Land Reclamation Boazd established the policy that on a case-by-case basis certain mines that were operated and largely reclaimed prior to the adoption of Rule 3.1.7 in 1993 should be treated less rigorously under Rule 3.1.7 than new operations and continuing operations. Specifically, the Boazd indicated that Homestake should not be required to characterize ground water at the Bulldog Mine as it relates to the flooding of the underground workings, and further indicated that similaz exemptions may be appropriate at other mines on a site specific basis. It is the Division's position that such an exemption from the requirements of Rule 3.1.7 would not be appropriate for application to the 9360 adit water at the Bulldog Mine. The justification for the Division's position is: The discharge of water from the 9360 adit was not anticipated or addressed in the reclamation plan through most of the life of the Bulldog Mine reclamation permit. The first appeazance of adit dischazge was in 1995, two years after the passage of Rule 3.1.7. Adit discharges can be managed through a number of mechanisms at the choice of the Operator. Such mechanisms include dischazge to surface water incompliance with a CDPS permit, evaporation in a lined pond, land application, or plugging for forced reinfiltration. Both land application and adit plugging potentially result in a dischazge to ground water, and would be regulated by the Division under Rule 3.1.7. The appearance of an adit discharge and the Operator's choice to plug the adit require modifications to the approved reclamation plan. To date, the Operator has filed four technical revisions related to the 9360 adit discharge. Based on the fact that the 9360 adit water is a potential source of ground water contamination that was not anticipated in the original approved reclamation plan, and is now being managed via permit modifications filed after the