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. ~ • Gold Hill Mill 7 March 27, 1995 and provide the slope gradient of each reach; (c) the application states that the upland diversion ditch above the tailing impoundment was certified by Ted Zorich Associates, and that a copy of the certification is included. The Division did not receive a copy of the certification with your submittal. 24. The Adequacy response submittal from COM, Inc. received by the Division on February 16, 1995, it is stated that 6 inches of rock will be placed on the tailing surface as a capillary barrier at the time of reclamation. Without test plot data or other verifiable reasoning, the Division will not approve a diminishment of the reclamation plan for the tailing impoundment found in Permit M-83-141, which specifies a 24 inch rock layer. Please commit to placement of 24 inches of well graded rock as a capillary barrier between the tailing surface and the topsoil layer, and provide revised reclamation cost estimates to cover the cost of hauling, placing, and smoothing the rock layer. Also, the Division believes that a layer of geotextile fabric will have to be installed on the tailing surface before the rock is placed. This is becoming a universally accepted procedure at tailing reclamation sites. Please commit to the installation of geotextile at the Gold Hill impoundment, and incorporate installation of the geotextile into your reclamation cost estimate. 25. In the adequacy response received from COM, Inc. on February 16, 1995, it is stated that groundwater "flow rates may be determined from the information learned out of these loggings". The loggings referred to are water table elevations to be measured in the existing monitoring wells. While water table elevations may be useful in determining water table gradient, in order to determine groundwater flow rate, formation hydraulic conductivity would also have to be measured. Please provide a proposal to measure the pertinent groundwater parameters, and subsequently determine groundwater flow rate. 26. In various locations within the permit application and adequacy responses, and in the portions of permit no. M-83-141 relating to the mill, as well as in discussions between COM, Inc. and the Division staff, a variety of monitoring and reporting procedures for the mill complex have been proposed. The Division will require that COM, Inc. consolidate these procedures into a concise monitoring and reporting plan that can be segregated into a separate folder in the permit file. The monitoring and reporting plan should specify, preferably in spreadsheet format, the types of monitoring to be completed, the frequency of the monitoring episodes, the parameters to be analyzed by the monitoring entity, and the data to be recorded from each monitoring episode as well as the method by which the data will be made available to, or reported to, the Division. Monitoring required at the Gold Hill Mill would be: (a) groundwater well sampling for water quality parameters and water table elevation;