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<br />Mr. James Cowart <br />December 17, 1997 <br />Page 3 <br />into the Hazel A adit in 1995, the DMG required that the mill <br />be maintained as a zero discharge facility unless a CDPS <br />discharge permit was obtained form the Colorado Department of <br />Public Health and Environment, Water Quality Control Division <br />(CDPHE). In it's letter date 7-18-95, the operator committed <br />to maintaining the mill as a closed circuit system. The 10-10- <br />97 conceptual reclamation plan states that after the water <br />currently in the Hazel A is pumped to the tailings pond, the <br />coffer dam and all Franklin equipment will be removed. Please <br />provide more detail how the wooden bulkhead and the approved <br />concrete and block bulkhead will be reclaimed. <br />Before the Hazel A adit is allowed to free drain, the operator <br />will first need to obtain either a discharge permit from the <br />CDPHE or a letter from that agency stating that a discharge <br />permit no longer will be required. This will be necessary <br />before any reclamation work is completed in the tailings pond <br />due to the permit requirement for a zero discharge. The only <br />other requirement in the approved reclamation plan for the <br />Hazel A is that the portal be sealed and safeguarded to <br />prevent access. <br />3.2 Mill Building and Contents - Please identify any reagents and <br />acid or toxic-forming materials at the mill, their quantities, <br />and their fate during reclamation. <br />3.3 Tailings Pond - The reclamation plan submitted with the <br />original permit application on December 12, 1994 stated that <br />'reclamation will concentrate on maintaining the structural <br />stability of the tailings dam, protecting the embankment from <br />erosion, and establishing the growth of a permanent cover of <br />indigenous vegetation on the tailings impoundment area.' The <br />resultant approved plan requires that the tailings in the pond <br />be covered with a geotextile layer, followed by 24 inches of <br />well graded rock, and then by a minimum of 4 inches of <br />topsoil. There is no provision in the approved reclamation <br />plan which specifies removal of the HDPE liner beneath the <br />tailings pond. Map Exhibit D-1, received by the DMG on July <br />20, 1995, shows contours of the reclaimed, revised tailings <br />area. <br />The conceptual reclamation plan submitted on October 10, 1997 <br /> <br />