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? .. , <br /> <br />Letter to Gwen Fraser -2- March 25. 1996 <br />the spray system. <br />2. In the COM, Inc. request for deadline reconsideration, the position <br />is taken that the pond, in its current configuration, does not pose a <br />threat to persons, property, or the environment. COM, Inc. further <br />expresses the opinion that the pond has the reserve capacity to contain <br />back-to-back 100 year floods. DMG does not agree with either of these <br />positions. In a closed circuit, zero-discharge impoundment, such as the <br />Gold Hill Mill tailing pond, reserve capacity to prevent discharge during <br />a design flood must be based upon the freeboard available after normally <br />anticipated non-flood inflows have occurred. DMG has already <br />demonstrated, in our letter to COM, Inc. dated 2/27/96, that reasonably <br />estimated normal inflows to the pond will exceed the currently available <br />storage capacity, leaving a zero reserve capacity for storage of design <br />flood inflows. This is clearly an unacceptable situation which can only <br />be rectified by timely installation of appropriate contingency measures. <br />in the pond. <br />3. At this time, the Gold Hill Mill tailing pond is in a relatively dry <br />condition. This condition would greatly facilitate installation of the <br />required spray system. With the onset of spring snowmelt and typical <br />spring precipitation events, the pond will begin to fill, the tailings <br />will become saturated, and working conditions in the pond will <br />deteriorate. If it becomes necessary for DMG to install the spray system <br />as part of an emergency response action, it is DMG's intention to assure <br />that such installation be facilitated by relatively dry working conditions <br />If you have any questions, please contact me. <br />Sincerely, <br />~~ <br />H. Bruce Humphries <br />Minerals Program Supervisor <br />cc: Richard Fanyo, Dufford and Brown, P.C. <br />C:\WP51\GOLDHILL.SP3 <br />