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JUI.- 5-95 WED 229 PM TESS~CT PRODUCTIONS FAX N0, :479713 P. 6 <br />o A set of objective inspection criteria based upon <br />engineering design requirements coupled with observable <br />chatacbcristics_ <br />o A defined interval and methvd of communication of <br />inspection resula to COM, Inc. tnaaagetnent and DMG <br />Staff. <br />o A defined method of working identified deficienrSes oa site <br />including, in the last resort, shutdown of a deficient <br />operation or procedure pending engineering/maaagement/ <br />DMG direction. <br />o A set of defined mandatory inspection points, supplemented <br />by specified periodic routine monituriag of activities. <br />o A corrective-action program incorporating mandatory <br />response by COM, Inc. management. <br />Miscellaneous Technical Comments: <br />Reference 11, Item 6 states is parr: "It is the Division's view that <br />the water behind the Hazel A bulkhead is process water .... It is <br />the Division's intention to require permit wnditions that will assure <br />that the Gold Hill Mill is azero-discharge facility, or that any <br />process water releases are properly permitted." The Committee <br />certainly endorses this position; however, recent events have <br />identified some practical problems. <br />In Reference i2 at Item 4, the Division states, "lt is clear based on <br />observations made during the 1ivision's 6/7/95 inspection report <br />(Reference 9), that the Gold Hill Mill water management plan, as <br />it is described in the application and es it is operand at the site, is <br />not sufficient to prevent discharges of tailings pond water to Cash <br />Gnkh. " I[ is possible w go further than this. Observation by the <br />Committee t;R. Mason) at the Haul A on May 30, 1995 showed <br />brisk outflow from behind the bulkhead, st an estimated five to tea <br />gallons per minute (gpm) rate. Impounded water at that time <br />appeared clear, and dte water level behind the bulkhead was high, <br />about eighoeen inches below the bulkhead top. The conclusion we <br />drew at the time was that tepid groundwater inflow was occurring <br />into the edit behind the bulkhead and that, had the bulkhead been <br />watertight, overtopping would certainly have occurred, probably <br />long prior to our arrival. Water inflow behind the bulkhead <br />