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<br />Memo to Gary Curtiss 3 December 1 1. 1997 <br />must be reiterated that land application of Hazel-A water was approved on an interim basis with <br />on-going quality testing. Land application was approved to forestall the less desirable results of <br />dam overtopping or unpermitted process water release. Land application is to be used only when <br />spray evaporation is not able to keep pace with tailing pond inflows. <br />8. [t is stated in section 3.7 of the Conceptual Reclamation Plan that post closure ground <br />water monitoring will be conducted on a quarterly basis for one year. Given the dearth of <br />baseline ground water quality data available for the site, and Colina Oro Molino's continuing <br />failure to comply with the ground water monitoring requirements in the approved permit, it is <br />unlikely that a year ofpost-closure monitoring will be sufficient to assess the potential for <br />ground water impacts. <br />Please note that I have made a few minor edits in your draft adequacy letter. I have struck the <br />sentence "This has been completed by the operator" from section 3.1 of your draft letter because <br />1 am not sure that the existing Hazel-A closure is adequate for the long-term. As I recall, there is <br />a substantial gap between the top of the hatch and the back (roof) of the adit. There is also a <br />utility borehole into the adit that will have to be plugged. Also, the hatch frame needs to be <br />further inspected by the Division to assure that it is adequately secured to the rib. <br />I think that the enumerated items above should be incorporated into the adequacy letter. This <br />document is available on the M-drive, as noted below, for your use. <br />cc: Carl Mount <br />m:\mi n\acs\goldh i I Lwpd <br />