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3.0 SITE DISPOSITION <br /> Disposition of containerized liquids, removed "non-authorized (waste rock) materials", and future <br /> groundwater monitoring requirements remain to be addressed subsequent to the completion of <br /> the composite liner system repair activities. Current status and proposed disposition methods for <br /> each are as follows. <br /> 3.1 Removed/Containerized Liquids <br /> As previously discussed, containerized liquids remain present within Tanks 1, 2, <br /> and 3. VRI retained the services of an independent third-party environmental <br /> engineering firm (RETTEW, Inc. of Golden, Colorado) to conduct sampling of the <br /> liquids and arrange for laboratory analyses in accordance with the approved <br /> protocols and suite of analyses as identified in Technical Revision No. 4. <br /> Sampling included discrete sampling of each of Tanks 1, 2, and 3, and, a composite <br /> sample, as well. Sampling was completed August 31, 2017 and samples were <br /> shipped via appropriate chain-of-custody requirements to ESC Lab Sciences in <br /> Mount Juliet, Tennessee. <br /> Laboratory analyses were completed and received by VRI on September 6, 2017; <br /> the complete laboratory report is provided as Attachment III: Containerized <br /> Liquids Sampling and Analysis Results. <br /> VRI proposes to (and herein requests written authorization from the Division to do <br /> so) place the now-containerized liquids back into the impoundment feature from <br /> which they were originally removed. <br /> Disposition of the containerized liquids in this manner would both: (a) ensure that <br /> said liquids would not be maintained within a re-certified and approved EPF and <br /> thus not be subject to potential release to the environment; and, (2)aid in precluding <br /> wind-borne dust generation from the residual tailing materials that remain in the <br /> impoundment <br /> 3.2 Stockpiled (Non-Authorized) Waste Rock Material <br /> The non-authorized material that was removed from the EPF was comprised of a <br /> mix of waste rock and "bank run" (i.e., previously in-place decomposed granite and <br /> surficial soils that were excavated to derive sufficient volume to cover the prior liner <br /> system) materials, both of which were procured from within the confines of the EPF. <br /> Proportionally, VRI estimates that the "bank run" material constituted in excess of <br /> 50% (by volume) of the "non-authorized material". To the extent feasible, the "bank <br /> run" material was segregated from the waste rock material during the removal <br /> action and separately stockpiled (still within the confines of the EPF) for use as a <br /> supplemental growth medium in support of future site reclamation activities. <br /> 7 <br />