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Mr. Jeff Deatherage - August 6, 2010 <br />Page Seven <br />Operationally, AGC envisions both the spray evaporation and land application would occur <br />during peak daylight hours to take advantage of temperature and wind effects - estimated at <br />about 10 to 12 hours per day, subject to impending seasonal reductions. The half-day <br />application limit would facilitate in-zone drain-down, and the multiple zone land application <br />concept would allow for sequential daily rotation (or a rotation schedule based on any <br />operational constraints imposed by DRMS) such that the potential for over-saturation of <br />affected areas would be significantly reduced or eliminated via natural drain-down. <br />Disregarding meteoric inflow contributions, and based on utilization of a 25 gpm pump <br />operating 12 hours per day, while assuming constant application is achievable (through <br />zone rotation), AGC envisions an estimated 28 to 30 day period would be required to <br />evacuate just the estimated 500,000 gallons of surplus (that volume above the 2-feet <br />freeboard line) water contained within the tailing impoundment. We would anticipate optimal <br />productivity could be sustained through mid- to late September, with the potential for <br />operational difficulties (and correspondingly reduced productivity) to evolve during <br />subsequent periods of freezing temperatures (e.g., from October on). <br />(3) In Order to Achieve Control of the Site Water Balance: Due to the seasonality <br />implications of the proposed mitigation plan (e.g., starting in August at the earliest, if <br />approved), provide authorization to AGC to undertake the above two actions continuously or <br />intermittently, at AGC's discretion, through next spring (i.e., June 30, 2011) in order to <br />sustain accessible underground workings and surplus water storage capacity sufficient to <br />accommodate the upcoming spring 2011 run-off (and infiltration) period. <br />AGC is confident that significant progress can be made toward rectifying legal issues <br />pertaining to water rights and well permitting during the interim period. Further, AGC should <br />have in its possession by that time a finalized water balance and water management <br />program and be in position to either implement true "zero discharge" water management <br />actions at the site, or, alternatively, file the appropriate application for a CDPS permit, if <br />deemed necessary. <br />We ask that the Division give due consideration to this request for the granting of an interim <br />"variance" or "authorization". In order for AGC to be effective in gaining control of the water <br />management aspects of the site prior to the onset of winter 2010 (and more importantly, spring <br />2011 run-off), we note that time is of the essence since there is a very brief window of favorable <br />weather conditions ahead in which to commence the dewatering, evaporation, and land <br />application processes. <br />Please note that the duality of this request process (requiring concurrent approvals or <br />authorizations from both DWR and DRMS) requires that any such approvals or authorizations