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-- are shown by the Operator to remain in the mining operation." Since this applicant has no approved mining operation and, by his own admission, no legal source of ore, he has by definition no "mineral reserves" and thus, apparently, no standing for a Permit under these Rules. Nevertheless, point 4 states in part, "It is the Division's view that a permit for the mill can be issued pending location of an ore source...." Please clarify the Division's position on this point. 3. Point 10 notes the applicant's desire that the mill building "...remain as a permanent feature following reclamation," with the suggestion that post-mining land use might be designated as "Industrial/Commercial, " or "Residential. " The first of these suggestions is in clear violation of County Zoning requirements; the second, while theoretically possible, certainly stretches the definition of a "residence" beyond reasonable limits (except perhaps for bats and such), We see the applicant's position as an attempt to evade the substantial costs of demolition and reclamation at this site and, absent some clearly identified public good to be obtained, we are opposed to allowing the operator simply to walk away from this facility. Please clarify the Division's policy in this area. 4. Point 20 states that seepage collection as described by the application is not occurring and would not be necessary since the impoundment is lined. We agree, provided that liner integrity is maintained. A system to assure early warning of liner failure (such as the piewmeter approach identified in point 28(t) and 29(a), makes excellent sense to us (see your point 26(e) also); we wonder if you agree. 5. Point 22 identifies the reyuirement for a containment plan for the mill building. Please note that actual operating history of this facility includes spillage out the man-door at the northwest corner of the building (due to a pump-seal failure). Thus, planning must not focus only on the lower levels of the facility. 6. Point 27(e) requires "...a complete description of the decant lines and underground water storage facilities." This description should include a discussion of the means whereby the entrainment of tailings slimes and their transport to the Hazel A adit is prevented, or at least minimized, since such transport obviously bypasses the safeguards established by use of the impoundment liner. Given the present condition of the decant system, it is virtually certain that at least some such transport has already occurred. The Division has recognized the existence of surface water escaping from this adit (refer to Point 2). We wish to point out the consequent potential exposure of humans and other biota to slimes~erived contaminants contained in that water. Although the Committee has no data showing a present hazard, ordinary prudence dictates that this issue be addressed ahead of a problem. 7. The above comment applies equally to Point 28(d), description of decant system extension, and to Point 28(f), tailing deposition protocol and water management. The use of unlined dam raises (presumably located at some specified minimum distance upstream from the existing lined starter dam face)