2017-10-19_INSPECTION - M2009076

• Permit No: M2009076
• IBM Index Class Name: Inspection
• Doc Date: 10/19/2017
• Doc Name: Corrective Action Resolution Notice
• From: Venture Resources
• To: DRMS
• Email Name: MAC
• Media Type: D
• Archive: No

any imported materials proposed to be utilized in establishing a lower-level working
platform; (4) a request for a VRI commitment to provide residual (temporarily stored)
liquids sampling and analytical results to the Division prior to disposition thereof; and, (5)
clarification of proposed timelines for completion of the Removal Action. VRI addressed
each of the concerns in a resubmittal of the Technical Revision No. 4 on or about February
1, 2017. The Division issued Approval of Technical Revision No. 4 on February 8, 2017;
and, Technical Revision No. 4 served as the basis for implementing the subject Hukill
Millsite Corrective Action.
In summary, the Corrective Action activities commenced on May 27, 2017 with the
evacuation of free liquids from the impoundment; said liquids were contained in three
sealed and/or covered containment vessels located on the access road that crosses the
top of the concrete impoundment wall (starter dam). Removal of the non-authorized solid
materials (waste rock and miscellaneous materials) also commenced on May 27, 2017,
and the overall (non-authorized material) removal effort was completed on or about July
12, 2017. VRI then visually assessed the extent of (observable) liner damage and
determined that repair and recertification was technically and economically feasible.
Colorado Lining International, Inc. ("CLII"), the selected liner repair contractor (and, the
initial installer of the previously-certified EPF composite liner system in 2011)was retained
to complete liner repair activities and repaired liner integrity testing. CLII initiated liner
repair activities on Wednesday, August 16, 2017, and all repairs (and vacuum box quality
control testing activities) were completed by Saturday, August 19, 2017.
VRI now considers the liner system to be fully repaired, intact, and re-certifiable as an
approved EPF, pending Division concurrence. VRI assures the Division that no materials
(solid or liquid) have been placed on or within the repaired liner system by VRI at this
juncture; and, proposed final material disposition procedures are elsewhere addressed
within this report. At such time written concurrence with VRI's re-certification request and
recommended disposition procedures is provided by the Division, VRI will conclude the
Corrective Action related onsite activities accordingly.
2.0 SUMMARY DISCUSSION OF REMOVAL ACTION ACTIVITIES
Prior to commencing initial material removal all free liquids were evacuated from the
impoundment via pumping to interim containment vessels placed atop the service
roadway that crosses the concrete barrier (starter dam) feature. Approximately 2,500
gallons were placed into "Tank 1", a 2,500-gallon capacity PVC tank. Approximately
4,000-gallons were placed into "Tank 2", a 16-ft. diameter(lined) above-ground swim pool
equipped with a floating cover system. A second 15-ft. diameter (lined) above-ground
swim pool ("Tank 3") equipped with a floating cover system was subsequently added to
accommodate remaining liquids and any liquids derived from precipitation events that
occurred during the removal action; at conclusion of the field efforts it is estimated that
"Tank 3" also contained approximately 4,000-gallons. At present, the estimated total of
10,500-gallons (more or less) of free liquid remains stored within the three containment
vessels pending Division concurrence with the VRI-recommended disposition method.
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