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Mr. Michael January 16, 2014 <br />AM -01 Application Adequacy Review 3 File No. M -1990 -057 <br />11. As noted in the Division's Adequacy Review No. 2 letter, the Division has requested that the <br />Applicant include cyanide in the ground water sampling suite. The Applicant indicated that <br />the previous mill operator did not utilize cyanide in the milling process. The cyanide which <br />was observed at the mill in 2009 was not approved for use in the mill. In addition, the <br />previous Operator demonstrated a willingness to ignore regulations by constructing, and <br />presumably using, an unpermitted well. The Division does not have enough assurance that <br />cyanide was not used at the mill. Therefore, the Division will require cyanide to be initially <br />included in the ground water sampling suite. If cyanide is not detected after four quarters of <br />sampling, then the Operator may submit a Technical Revision to modify the parameters <br />included in the sampling suite. <br />12. The Applicant has proposed using the water quality data collected by the EPA as background <br />conditions for groundwater quality. There are several factors to consider when selecting <br />water quality data to be used for background conditions. Any wells which will be used for <br />background conditions must be in the general vicinity of the mill site and must be completed <br />into the same aquifer which could potentially be impacted. The water quality data provided <br />to the Division primarily was obtained from shallow alluvial wells; the useable aquifer <br />beneath the mill site is at a depth of 80 — 100ft. In addition, there are nine parameters which <br />the Operator has agreed to sample for which were not included in the sampling of the EPA <br />wells. According to Regulation No. 41 — The Basic Standards for Ground Water, Interim <br />Narrative Standards may be applied to all groundwater to which standards have not already <br />been assigned. The Interim Narrative Standards are to be maintained for each parameter at <br />whichever of the following levels is less restrictive: <br />a) Existing ambient quality as of January 31, 1994, or <br />b) That quality which meets the most stringent criteria set forth in Tables 1 through 4 of <br />`The Basic Standards for Ground Water' <br />The EPA water quality data was primarily obtained after 1994 and the Division is unable to <br />determine from the available information that there was no new or increased sources of <br />contamination initiated in the area in question subsequent to that date. The Division will <br />consider any additional EPA water quality data which meets the above criteria. Alternately, <br />the Applicant may use the most stringent criteria set forth in Tables 1 through 4 of The Basic <br />Standards for Ground Water or the Applicant may collect five quarters of background data <br />from the wells located at the mill site. If the Operator chooses to collect five quarters of <br />background data, the Division will allow the Operator to run the mill while the water quality <br />data are being collected as long as monitoring of the background well begins prior to mill <br />start -up, and it can be demonstrated that the first five quarters of mill operations will not <br />affect groundwater quality in the background monitoring well. Please respond. <br />13. The Division is currently reviewing the Applicant's stormwater management plan. <br />Comments regarding the stormwater management plan will be forthcoming. <br />14. The Division will calculate the final Financial Warranty amount once all of the adequacy <br />issues have been addressed. <br />