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<br />June 8, 1990 <br />Page 5 <br /> <br />through 18 inch galvanized culvert to the clean <br />impoundment. The Division interprets this state <br />that an 18 inch galvanized culvert will be constrt <br />way from the point of diversion at Columbia Ditch <br />cell of the impoundment. If this interpretation <br />please verify. If it is not, please provide all <br />requested. <br />11 of the <br />it to mean <br />.d all the <br />the clean <br />correct, <br />formation <br />In the attached report RRI has provided a descripti n of the <br />diversion that will be employed to carry raw water into the <br />impoundment. This approach to diversion has been used hi tonically <br />without incident. <br />As a no-discharge operation the Alma Placer Mine is not object to <br />the NPDES categorical standards for the Gold P1 cer Mine <br />Subcategory found at 40 CFR 440.140. Regardless, th t body of <br />regulations provides specific performance standards for erms, but <br />does not specify performance standards for diversion s ructures. <br />The regulations do provide that the diversions must be ffective, <br />must protect from sudden and catastrophic failure, a d must be <br />maintained. (See 40 CFR 440.148(e)). RRI asserts that the <br />existing diversion system satisfies those requirements. <br />EXHIBIT L - RECLAMATION COSTS <br />Our May 21, 1990 correspondence indicates that a <br />$40,600.00 will be necessary. Please provide <br />estimate, or concurrence with our recommendation. <br />See comments immediately below. <br />EXHIBIT L - RECLAMATION Cost Estimate <br />Doze tails from 1.5 day operation <br />No comment. <br />Push embankment of pond 1 to 4~ slope <br />Phase I Bond of <br />a re ised cost <br />$ ,889.05 <br />$ 13,208.00 <br />RRI's concurrence with this figure is dependent on <br />response to our comment on finished grading, immediate <br />Finish grade 27 ac @ $555.54/ac $ <br />e MLRD's <br />below. <br />,999.58 <br />RRI asserts that the costs to push the embankment of p nd 1 to 4$ <br />are duplicated in the finish grading, and the grading costs are <br />unreasonably high given the pre-disturbed nature of th mine site <br />and the historical post-mine site performance standard p oposed for <br />