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The waste rock material now resides on the first-level bench area immediately <br /> upslope of the lined impoundment in an "over-the-bank" dumped configuration <br /> exhibiting a natural "angle of repose". VRI considers this material to represent a <br /> future "ore" resource that will be subject to processing at such time that the <br /> associated Hukill Mill operations are released from the currently imposed "Cease <br /> and Desist" order, and operations can be restarted. <br /> Inasmuch as the waste rock material is considered future "ore" and given that it <br /> resides within the confines of the EPF, VRI proposes to leave the material in place. <br /> Upslope diversions (on the second-level bench) and a downslope perimeter berm <br /> (on the first-level bench) have been constructed to divert run-on and constrain <br /> material movement, respectively. Ongoing monitoring will be carried out in <br /> accordance with the site's Stormwater(NPDES) General Permit and the associated <br /> Stormwater Management Plan (SWMP); and, the material will be managed in <br /> general accordance with recognized Best Management Practices (BMPs). This is <br /> consistent with the "non-authorized material" disposition method described within <br /> the Division-approved Technical Revision No. 4. <br /> 3.3 Groundwater Monitoring Program <br /> Throughout the duration of the Corrective Action Program (and initially effective with <br /> the Division approval of Technical Revision No. 3), VRI has been operating under <br /> an enhanced groundwater monitoring program wherein the initial (approved) DRMS <br /> Permit No. M-2009-076 quarterly monitoring was voluntarily increased in frequency <br /> to monthly (and thereafter made a condition of Permit No. M-2009-076) by the <br /> Division). <br /> VRI herein provides (as Attachment IV: Monthly Groundwater Monitoring <br /> Reports) the monthly monitoring reports for the period January 2017 through the <br /> most recent monitoring event of September 2017. With the exception of the June <br /> 29, 2017 monitoring event, all events recorded both upgradient and downgradient <br /> monitoring wells as "dry". While a single instance of liquid presence in the <br /> upgradient monitoring well was recorded on June 29, 2017 (approximately 10 ml), <br /> there was insufficient volume for sample analysis; and, given that it was the <br /> "upgradient" monitoring well, there is no evidence to suggest or indicate that there <br /> has been a release to groundwater as a result of the "compromised" liner system. <br /> Inasmuch as the liner system has now been repaired and fully restored to what VRI <br /> considers to be a re-certifiable condition, VRI herein seeks written authorization <br /> from the Division to return to a quarterly monitoring status commencing with <br /> January 2018 (meaning VRI would not conduct monitoring in October, November, <br /> or December 2017). Thus, the January 2018 monitoring event would reflect the <br /> conversion back to quarterly monitoring, if so approved by the Division. <br /> 8 <br />