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-~ <br />Memo - Dave Bucknam - 2 - May 29, 1991 <br />I would make the following comments: <br />- Rockcastle had ACZ Engineering perform engineering observations of the <br />impoundments on August 22, 1990, and September 11, 1990. The report <br />discussed structural weaknesses, erosion and sediment levels of the ponds <br />per Rule 4.05.6(131. It was not submitted as the semi-annual pond <br />inspection report, and was not retained with the records at the site. <br />It was an engineering response to paragraph III(21 of the Agreement. <br />- The Division acknowledges that the violation incorrectly referenced <br />Pond 1. <br />- Rockcastle's permit application discusses both NPDES sampling and <br />hydrologic monitoring plan sampling. The former requires sampling on <br />weekly or monthly intervals when water is discharging from the four ponds <br />at the site, with quarterly reporting. Rockcastle complied with their <br />reporting requirement, but it is in no way clear that they complied with <br />their sampling requirement. (However, Rockcastle's NPDES sampling is not <br />the subject of NOV C-91-0031. The hydrologic monitoring plan <br />requirements were imposed on the company through Technical Revision 2, <br />approved September 4, 1986. This plan requires a different frequency of <br />monitoring at six locations when operations are occurring at the site <br />than when the site is inactive. I believe that Rockcastle was operating <br />as an active mine when they started performing earthwork at the site, and <br />thus did not perform 10 field samples, 9 full suite samples, and a spring <br />and seep survey in 1990. <br />The following items are enclosed for your reference when reviewing this <br />request for vacation: <br />- Settlement Agreement, dated June 6, 1990; <br />- Ten Day Notice X-91-02-116-004-TV 3; <br />- NOVs C-91-002 and C-91-003; <br />- May 6, 1991 letter from Parcel, Mauro, Hultin and Spaanstra; <br />- May 20, 1991 vacation request from Parcel, Mauro, Hultin and <br />Spaanstra. <br />/ern <br />Attachments <br />cc: Steve Renner <br />5910E <br />