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Stateataat of Position <br />Paq• 3 <br />water in the pipe and the stress on the pipe joints while elevating <br />and moving the pipe). <br />Third, response to alleviate the problem was swift by hutdown of <br />the freshwater pump and sump pumping of pooled fluff s back to <br />primary containment (thereby minimizing the potentia for slow <br />seepage into the ground). All fluids were returned to primary <br />containment within 30 minutes. <br />To gain an appreciation of the issue of site containmen , BMRI has <br />prepared a plan view drawing of the facility which demon trates the <br />facility setting and drainage gradients away from the v rious mill <br />facilities towards the tailings pond. There is a c nsiderable <br />distance placed between the mine location, Rito Seco Cre k, and the <br />mill/tailings facility. This was designed for a ver specific <br />purpose: To provide a tertiary containment system f r all ore <br />processing facilities to force drainage away from the tentially <br />most significant water pollution risk area (Rito S co Creek) <br />towards a containment facility (the mill tailings pond). In <br />addition to site drainage, the mill facility location had the <br />advantage of being placed over a 200-foot layer of low pe meability <br />soils that severely limit vertical migration of fluids were a <br />release to occur. Thus, the facility has been desig ed around <br />three "layers" of containment: Primary lining syste s such as <br />tanks, pipelines, and synthetic liners; secondary line s such as <br />secondary pipes, concrete containment, or compacted soil, and <br />tertiary containment such as site drainage to primary c ntainment <br />and ultimately naturally occurring ground conditions. It is <br />important to note that the Division recognizes this "layered" <br />containment of both site drainage and naturally occ rring low <br />permeability soil conditions at the mill facilities loca~ion area. <br />Item 5 of the adequacy response letters to the Division in 1990 <br />addressed in particular the concern the Division had regarding <br />spills that would not result in a discharge from the 'facility. <br />BMRI provided the Division information regarding thin tertiary <br />containment (see Attachment 1). Thus, tertiary contai went is a <br />key component of the overall facility design and operati n and was <br />addressed in the permit approval process. In this circum tance the <br />tertiary containment functioned as contemplated in the ermit and <br />facility containment was nat breached. <br />BMRI has taken several steps to rectify this problem near}-term and <br />ultimately present a final resolution. First, telemetry from the <br />well field and reclaim water systems has been improved do provide <br />remote pump shutdown (in the control room), an audible alarm has <br />been installed in the control room to notify the Mill Ope ator when <br />the process water tank is 85t full, and repair of the ouplings <br />that were damaged during the pipeline relocation has 'occurred. <br />Because the overall gradient from the process water tank ~o the new <br />tailings pond elevation is nearly flat, BMRI is in the p ocess of <br />