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<br />Memo to Steve Shuev 6 June 15. 1998 <br />adoption of Rule 3.1.7, this water would not be exempt under the Board's policy for previously <br />operated and lazgely reclaimed mines. <br />8. A component of the Board's finding that Homestake would not be required to characterize <br />ground water related to flooding of the Bulldog Mine was based on the Board's opinion that it would <br />be difficult and expensive to determine ambient ground water quality. It was the Board's expressed <br />opinion that ground water upgradient of the Bulldog ore body would not be representative of ambient <br />ground water quality suitable for comparison with ground water downgradient of the underground <br />mine workings. This is because the ground water would likely have become naturally contaminated to <br />some extent by interaction with the ore body even if the site had never been mined. This issue does not <br />apply to characterization of ambient water quality upgradient (above) the 9360 adit because the <br />Operator's working hydrogeologic model for the site assumes the Creede Formation is non- <br />mineralized. At least, there is no indication that the Creede Formation would be inhomogeneously <br />mineralized. As such, the upgradient water will be suitable for determination of ambient water quality. <br />9. It is stated in the Operator's Technical revision TR-007 adequacy response letter dated 3-16-98 <br />that: <br />...the objective of the adit plug is to force shallow seepage back out into the Creede Formation <br />rather than allowing it to preferentially flow out the portal. Since the source of the water is the <br />Creede Formation, this will provide along-term solution to adit seepage that closely reproduces <br />the natural conditions that existed before mining. That is, water originating from the Creede <br />will continue to flow in this formation. Since the Creede Formation is non-mineralized, the <br />water entering the adit and then flowing back into the Creede Formation will be relatively <br />unaffected by the mine. <br />If through characterization of ambient ground water quality it can be demonstrated that water flowing <br />back into the Creede Formation in a plugged adit scenario is relatively unaffected by the mine, then the <br />Division could permit reinfiltration of 9360 water without pretreatment or the establishment of numeric <br />protection levels and point(s) of compliance. <br />I would suggest that this memo be shared with Homestake, and that the Division and Homestake enter <br />into discussion of procedures and deadlines prior to issuance of a formal notice under Rule <br />3.1.7(3)(b)(ii)(A). <br />Attachment(s) <br />cc: Bruce Humphries (w/attachment) <br />Harry Posey (w/auochment) <br />c:\...\bulldog5.wpd <br />