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.. DISCUSSION Overall, the previous Operator pattern of partial, tardy compliance with requirements appears to be still intact. Of primary concern is the fact that, as of this date, available pond freeboard is minimal, and the margin between the water level at the top of the decant standpipe and the level at first water contact with soil at the dam face is nil to negative. We are gratified, of course, to see the removal of junk from the millsite and the rehabilitation of the diversion ditches, site berming, and storm-water ponding. But this does nothing to relieve our major concern, that of a repetition of the illegal discharge of process water and entrained tailings solids to Cash Gulch that occurred this Spring. We fully share Division Staffs concerns regarding overall site water balance - we raised those concerns quite some time ago as you know, and we are deeply distressed to see how the available constructionlrepair time has been squandered. Weather here is deteriorating rapidly with the onset of winter. Temperatures are falling, together with achievable evaporation rates. Significant snowfall could occur at any time, making further work on the pond liner far more difficult (and expensive), thus encouraging yet further delays. In sum, we are rapidly being forced into a position where we must choose between direct pond water contact with a raised dam crest of unknown and questionable integrity and unpermitted discharge of Hazel-A effluent to Cash Gulch. It is worth noting the following: o On February 28, 1995, a Notice of Violation and Cease and Desist Order was issued by the Board which stated, at Item 1, "Cease and Desist on the use of the mill and tailings impoundment unfit a properly engineered plan is submitted to the Division in the form of a new permit application which solves the problems of a lack of sate freeboard in the impoundment, the instability of the currently deposited tailings near the embankment, and the cleanup of the tailings in the building." (Emphasis added.) o The DMG Staff Inspection Report dated June 7, 1995 stated in part, "... (T)he Division will not approve the new Gold Hill Mill application ... until a viable water management plan is reviewed and approved. ... (Alll flaws in the liner must be repaired by July I 1995•„ (Emphasis added.) o The DMG response letter to COME dated June 9, 1995 states at item 6, "... It is the Division's view that the water behind the Hazel-A bulkhead is process water .... It is the Division's intention to require permit conditions that will assure that the Gold Hill Mill is a zero-discharge facility, or that any process water releases are properly permitted." And, at item 8, "...(Alll but de minimis amounts of tailings would have to be cleaned out of the Hazel-A adit and returned to the pond ... as an ongoing maintenance task." (Emphasis added.)