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<br />etatamaat o! Position <br />Paga ~ <br />re-establishing a positive 1$ gradient from the tank t~o the pond <br />via a fill ramp upon which a new welded inner pipe and flanged <br />outer pipe (double pipe) will be installed. <br />BMRI believes strongly double pipes are superio in this <br />installation due to the gradient problem previously me tinned and <br />the location of drainage path in relation to the cut s ope to the <br />west of the mill facility (i.e., a lined ditch as the d vision has <br />suggested may fill with sloughing material and/or run- ff). <br />Finally, BMRI would note to the Board and Division <br />virtually impossible to build fail-safe systems partici <br />human error can be introduced. This is why redundancy <br />response procedures are planned and included in 1 <br />document. Section 9.3 of BMRI's approved San Luis <br />Response Manual states "Incidental controllable spills ' <br />pose a human health or environmental hazard shall b <br />immediately by trained personnel." Thus, it is appare <br />BMRI and the Division that release events can or may c <br />obvious issue to all parties is the significant <br />environmental threat and the provision of an appropriate <br />Given the data presented BMRI believes this was non-e <br />this instance and the response was immediate and effect <br />In conclusion BMRI believes that although a release <br />fluids from piped containment did occur, no violation re <br />to the containment of fluids within both the secondary ar <br />containment systems, the extremely low levels of cyani <br />which resulted in no risk to human health or the envirc <br />BMRI's rapid response towards alleviating the immediate <br />:hat it is <br />larly when <br />and proper <br />he permit <br />Emergency <br />.hat do not <br />a remedied <br />nt to both <br />ccur. The <br />e of the <br />.response. <br />Kistent in <br />eve. <br />t process <br />;ulted due <br />l tertiary <br />e present <br />ment, and <br />concern. <br />