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• <br />Minutes, April 22-23, 1992 <br />,~,.i DRAFT <br />Subject To Board Approval <br />per million total and 3.8 parts per million weak acid dissociable <br />cyanide in the tailings and collection ponds, including the leak <br />detection system. Staff further recommended that the Board grant the <br />Division the authority to issue an immediate cease and desist order, if <br />the Division finds evidence that cyanide from the mine poses a threat <br />to human health or to the environment. <br />At this time, Staff discussed the Division's review of the technical <br />aspects of the technical revision and recommendations for corrective <br />actions to abate the violation. Staff presented EXHIBIT B, the <br />Division's 12 requirements for abatement of the violation, along with a <br />discussion of those requirements. Staff said the document represented <br />some minimal changes made at the operator's request and also included <br />additional commitments by the operator to abate the violai~ion. <br />Staff referenced Exhibit A and stated that the first 4 items addressed <br />the operator's immediate response to the problem at the site and that <br />the operator had submitted information, regarding 1) an increase in <br />tailings area security, submitted April 3, 1992 and 2) assessment of <br />the environmental impact of the violation, submitted April 13, 1992. <br />Staff discussed those submittals and said the those requirements had <br />been satisfied. Item 3 requires an increase in freluency of all <br />tailings and environmental monitoring to twice monthly. Staff said the <br />Division is satisfied that the operator has agreed to the requirement. <br />Staff said that Item 4, requiring detoxification of the tailings, has <br />been partially satisfied by the operator, in that the operator has <br />committed to providing this information within 30 days. The operator <br />has chosen zinc ferrous sulfate (CyTox) for detoxification and this has <br />been approved by the Division. Staff said the Division is partly <br />satisfied with the operator's response to this requiremert, because the <br />approved 3.8 and 4.4 cyanide limits will not be raised. The operator <br />has submitted a technical revision covering this requir?ment, but has <br />stated that the approved levels cannot be obtained at this time. <br />Staff said Item 5 requires the operator to repair the primary liner, if <br />a leak is detected, and to increase additional monitoring and analysis <br />of the system. The Division is satisfied that the operator committed <br />to the requirement in an April 16, 1992 letter. <br />Staff said Item 6 directs the operator to conduct an evaluation within <br />the next month to reevaluate all of the monitoring facilities in place <br />around the tailings area and demonstrate their adequacy to the <br />Division. If the monitoring facilities are found not to be adequate, <br />the operator is required to submit a design for facilities that would <br />be adequate. The Division also required construction of monitoring <br />wells. The operator committed to this requirement in the April 16, <br />1992 letter and verbally to the requirement for necessar.i modification <br />of the plan on April 22, 1992. <br />Staff said Item 7 directs the operator to determine the cause of <br />failure in their ore processing methodology, including the treatment <br />system, in order to determine needed changes to meet the approved <br />