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Statamant of Position Paga 2 make-up to the process water tank continues) since the fresh water feed pumps are not shut down. Overflow of the process water tank into the reclaim overflow line begins. 3) While attempting to move the reclaim overflow rain line, the line is flexed damaging both the inner pie coupling and outer pipe coupling. Leakage begins to occur. Approximately 5-7 minutes after being observed, the fresh water feed pump to the process water tank islshut down. Overflow continues 2-3 minutes. 4) A total of approximately 10,000 gallons m ximum has escaped the pipe of which approximately 1500 allons has drained into a drainage ditch sump at the a ge of the tailings pond but within tertiary containm nt. The remaining 8500 gallons flows onto the clay li er in the tailings pond construction area but within secondary containment. 5) Remedial pumping to primary containment and r placement of saturated clay liner is immediately initia ed. 6) Fluid samples and soil samples are retrieved, reserved, and sent for outside analysis (WAD and total c anide) at Core Laboratories. The Division was provid a fluid sample for comparative analysis. 7) Fluid sample results are received indicating .16 ppm total cyanide and .16 ppm WAD cyanide (these alues are below the federal drinking and groundwater advisory limits). Soil sample results indicate non-detestable for both WAD and total cyanide. The Division was on-site conducting a tailings facility construction inspection when the event occurred and (therefore witnessed items 3 through 6. As previously mentioned a fluid sample was provided to the Division for separate analysis. There exist several key issues to this incident tha~ require detailing. First, it is important to note that the fluid released and verified by independent sampling did not at any time represent a risk to human health or the environment. This was d e to two factors: The cyanide level in the tailings facility w ter pool that is brought into the process water tank is extrem ly low - generally less than 2 ppm WAD cyanide and second, the reclaim water is normally mixed with fresh water in the process water to k (fresh water from the farm well system approximately 6 miles nor h of the mine site). Second, all the pipelines previously identified are not normally relocated or moved except during this lane time construction sequence. This being the case, random pipeline flexure that results in a joint or coupling failure is xtremely remote. (i.e., this was an extremely unusual event to move the pipeline and pipeline failure resulted due to the added eight of