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<br />Mr. James Cowart <br />December 17, 1997 <br />Page 6 <br />grouted closed. If not, they will need to be removed. The <br />operator had submitted reclamation costs to remove the <br />pipelines but not to regrade or revegetate any disturbance. <br />I believe this indicates the pipelines are not buried and will <br />need to be removed. <br />c) Reclamation of the pond and Hazel A decant lines. <br />d) Sealing the Time Mine, if this has not been already completed. <br />Allen Sorenson's comments: <br />1. In section 2 of the Conceptual Reclamation Plan, it is stated [hat the Gold Hill Mill is set up <br />to use drainage water from the Hazel-A adit as process water. Tn fact, in order to use the Hazel-A <br />water, the operator would have to obtain a well permit from the Office of the State Engineer. Since <br />the operator is consuming Hazel-A water continuously through evaporation, even when the mill is <br />not running, a well permit must be obtained. The Division raised this as an issue in an inspection <br />report dated 8/5/96. In response, the operator applied for a well permit on 9/11/96. A check of the <br />State Engineer's records indicates that the well permit application was found inadequate and was <br />returned to the operator on 9/30/96, with no subsequent action taken by the operator to obtain the <br />pemrit. As such, the operator is currently consuming water from an unpermitted well (the Hazel-A <br />adit).. <br />2. Tn section 3.1 of the Conceptual Reclamation Plan, it is stated that operation and maintenance <br />of the Hazel-A adit will be the responsibility of the owner once it has been pumped down and all <br />Franklin equipment and piping are removed. It was the operator, Colina Oro Molino, that plumbed <br />the Hazel-A into the mill process water circuit, and it was Colina Oro Molino that inadvertently <br />sluiced tailing into the Hazel-A. It was these actions that created the requirement for a CDPS permit <br />to dischazge ground water collected in the adit. In accordance with Water Quality Control Division <br />and Environmental Protection Agency policy, the ground water discharged from the Hazel-A adit <br />prior to Colino's actions would have been a low priority for CDPS permitting. As such, it is the <br />operator's responsibility, not the landowner's, to maintain the Hazel-A in a zero-dischazge <br />configuration or to assure that any dischazges are incompliance with the Water Quality Control Act. <br />If the operator disconnects the decant line that plumbs the pond to the Hazel-A, and if the operator <br />demonstrates to the satisfaction of the Division that all tailing and other introduced contaminants <br />have been removed from the adit, and if the operator secures a document from the owner of the adit <br />that he will be responsible for ground water inflows to the adit, the Division could release the <br />operator from on-going compliance with the permit as it regards the Hazel-A adit. Alternatively, the <br />operator could, as your draft adequacy letter states, petition the Water Quality Control Division for <br />a finding that discharges from the adit do not require a CDPS permit. <br />