Laserfiche WebLink
revoked (i.e., declared by the Board to be "void" and no longer useable for its intended <br /> purpose). As part of the March 3, 2016 Order, the Board required the Operator to "Cease <br /> and Desist" any further activity at the site except those activities: (1) approved by the <br /> Division, in writing, as necessary to comply with the conditions of the Order; (2)to prevent <br /> damage to off-site areas; or (3) to protect public health and safety, until corrective actions <br /> have been resolved to the satisfaction of the Division. Further to this, the Board imposed <br /> upon the Operator ("VRI") the following Corrective Action: "the Operator shall, within 90 <br /> days of the effective date of this Order, file a permit revision addressing the process <br /> whereby the tailings impoundment may be recertified as an Environmental Protection <br /> Facility, in accordance with the conditions of the permit and the Act and Rules". <br /> VRI thereafter (on or about May 20, 2016) submitted Technical Revision No. 3: <br /> "Composite Liner System Corrective Action and Recertification Plan for the Hukill <br /> Mill Site", wherein VRI committed to: (1) cease all site activities, with the exception of <br /> ongoing monitoring and reporting actions; (2) maintain all run-on/run-off control features <br /> in a functional manner to ensure all non-authorized materials remained contained within <br /> the confines of the EPF; (3) ensure site security to preclude unauthorized access; and, (4) <br /> retain a Colorado Registered Professional Engineer to oversee aspects of developing and <br /> implementing a Corrective Action Plan. The proposed Corrective Action Plan included: <br /> (a) retaining an independent environmental contractor to carry out an enhanced (higher <br /> frequency) groundwater monitoring program; (b) engaging a qualified liner installation and <br /> repair firm to aid in defining an appropriate liner inspection and repair approach; (c) <br /> defining an appropriate removal methodology; (d) retaining a contractor to conduct the <br /> removal of the non-authorized materials from the liner system; and, (d) ensuring that the <br /> composite liner system repairs were carried out in a manner that ultimately achieves a"re- <br /> certification" of the EPF. <br /> VRI's Technical Revision No. 3 submittal resulted in the Division issuing a June 30, 2016 <br /> Adequacy Review (No. 1) letter indicative that the Corrective Action Plan, as submitted, <br /> was considered to be "conceptual" in nature, and therein the Division requested an <br /> incremental level of detail on various aspects of the Plan. This resulted in VRI providing <br /> an August 8, 2016 response to Adequacy Review No. 1 addressing each of the stated <br /> concerns, and Technical Revision No. 3 was "conditionally" approved by the Division on <br /> August 18, 2016, subject to: (1) VRI providing (as a separate and subsequent Technical <br /> Revision No. 4) a detailed scope of work for the Removal Action Plan; (2) submittal of said <br /> Removal Action Plan within 120 days of the approval of Technical Revision No. 3; and, <br /> (3) the revision of the groundwater monitoring frequency from quarterly to monthly. <br /> VRI submitted Technical Revision No. 4: Detailed Scope of Work on or about <br /> December 7, 2016, and the Division responded on December 28, 2016 with Adequacy <br /> Review No. 1, requesting supplemental information, to include: (1) a request for site <br /> mapping depicting various stockpile and staging areas, etc.; (2) the need to identify the <br /> material source and compaction method for the proposed stockpile containment berm; (3) <br /> the need to identify the source of onsite materials and/or provide "clean certification" of <br /> 2 <br />