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<br /> <br />On another matter, we aze currently reviewing your November 3, 1998, adequacy letter to <br />CC&V. We will submit additional comments. However, at the outset, we continue to be <br />concerned about the lack of any analysis by CC&V of the expected quality of the dischazge from <br />the free-draining heap leach facility upon cessation of gold production. As noted in previous <br />letters, simple predictions (and monitoring) based on WAD cyanide levels alone is scientifically <br />and legally unsupportable. Without a full analysis of the predicted quality of the heap discharge, <br />it is impossible for the DMG/MLRB, let alone CC&V, to know whether all environmental <br />protective quirements of [he Act and the Rules will be met. 1 am attaching the technical <br />document titled "Cyanide Uncertainties" produced by the Mineral Policy Center [hat supports <br />our content n that discharges from heaps may pose severe risks to [he environment and thus <br />must be rep wed in any credible agency decisionmaking process. The issues raised in that <br />document ust be reviewed by the DMG/MLRB in this case. <br />1 appreciat he opportunity to bring these serious concerns to your attention. As a fundamental <br />matter, due o the acknowledged need for CC&V to submit a full reclamation plan for <br />DMG/publi review, it will be impossible for [he public to adequately review such a plan prior to <br />the Decem r MLRB meeting. CFV looks forward to the opportunity to submit additional <br />concerns as he permit process continues. <br />Since~~, <br />,~~,~ <br />,~>fog "r Flynn <br />v: Attorney for Citizens for Victor! <br />Cc: Mik Long, DMG (Fax only) <br />Bru Humphries, DMG (Fax only) <br />Ste Brown, Attorney General's Office (Fax only) <br />Dr. obert Moran (Fax only) <br />Bill lymer, CFV (Fax only) <br />