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~~ <br />Memo - BMG Monitoring Inadequacy <br />page 2 <br />disposal facility and the groundwater wells in the vicinity of <br />the tailings disposal area will be monitored monthly with the <br />results reported monthly." <br />My review of the 1989, 1990 and 1991 annual reports for BMG discerned <br />only one water quality analysis report for the leak detection system <br />(@ LD )30) and one analysis for the tailings area slurry (@ TP 130). <br />Both of these samples were collected on January 30, 1992. The <br />tailings slurry sample showed Cyanide levels (Free Cyanide = 170 ppm, <br />Total Cyanide = 240 ppm, and W.A.D. Cyanide = 210 ppm) far in excess <br />of the permitted characterization of 4.4 ppm. Further, the leak <br />detection sample reports elevated Cyanide levels (Free Cyanide = 80 <br />ppm, Total Cyanitle = 120 ppm, and W.A.D. Cyanide = 99 ppm), <br />indicating that the primary liner is leaking. Water quality <br />monitoring results have only been reported for one of the ground <br />water monitoring wells in the vicinity of the tailings disposal area, <br />well M-9. These results have been reported for quarterly samples, <br />rather than monthly. However, none of the water quality results <br />reported for well M-9 show any detectable Cyanide. <br />Based upon these observations, it is my conclusion that BMG has not <br />satisfied the monitoring commitments contained in their amended <br />permit. They have failed to monitor and report the drainage from the <br />tailings disposal area underdrain and leak detection system. <br />Further, they have failed to monitor and report the ground water <br />wells in the vicinity of the tailings disposal area on a monthly <br />basis. I believe these omissions to be serious, particularly in <br />light of recent developments. I recommend that we present these <br />concerns to BMG and request that they provide the monitoring <br />information, if they collected it. If we determine that BMG has <br />failed to meet its monitoring commitments, I recommend the Division <br />issue a separate Notice of Probable Violation (NOPV) for failure to <br />comply with the approved plan's monitoring obligations. <br />cc: Bruce Humphries <br />Mike Long <br />JP/Jp <br />Doc. No: 2384E <br />