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It would seem that DMG holds an interest in potential CERCLA actions at the Bulldog <br />mine because (a) DhIG still holds a permi~ for the site and (b) the operator is completing <br />studies requested by DMG. Moreover, DMG was critical of EPA's original PA results <br />due to the method that EPA employed to determine background water quality. <br />If Homestake's water quality assessment shows that the waste rock does not come in <br />contact with surface flow in Windy Gulch, and if the assessment shows that groundwater <br />seeps do not come in contact with either the 9360 or 9700 level waste rock, and if it can <br />be shown that Homestake operations have not lowered the water table, locally, then I <br />believe it would be most reasonable to conclude that the Homestake operation has not <br />affected water quality, except through contact of stormwater with waste rock. Provided <br />stormwater flows are exempt from water quality standards, there would appear to be no <br />reason to include the Bulldog operations in Windy Gulch in any future CERCLA action. <br />As indicated by former miners and the Chief Geologist at Bulldog, there appeazs to be a <br />relation between events at Bulldog and hydrology of Willow Creek. Apparently, after the <br />pumps were shut off at Bulldog, flow from Nelson Tunnel to Willow Creek increased. In <br />addition, seeps may have developed in the underground museum on Willow Creek about <br />that same time. Considering the local topography, local geology, and mining history at <br />Bulldog, it is feasible that the hydrology azound Bulldog could indeed affect flow from <br />the Nelson TunneUCommodore complex and possibly the underground museum. The <br />Nelson Tunnel is lower in elevation than the Bulldog 9360 portal, and the mining <br />museum is lower in elevation than the Nelson Tunnel. Whether Bulldog operations - i.e. <br />cessation of pumping -can be used to tie Bulldog to a CERCLA action involving the <br />Nelson Tunnel, I believe, would NOT be a DMG issue. <br />Before meeting with Homestake, I believe it would be prudent to review the Bulldog <br />information including the monthly monitoring reports, the eology/hydrology/topography, <br />and any information that might have been collected by BKS at local meetings of the <br />Willow Creek Reclamation Committee. At the moment, it is feasible that the Bulldog <br />operation would not qualify for CERCLA status, and that EPA's Preliminary Assessment <br />has fostered inappropriate perceptions about this mine's contributions to surface water <br />quality. <br />cc: Steve Shuey <br />Allen Sorenson <br />Bruce Stover <br />