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2019-01-31_PERMIT FILE - M2018053
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2019-01-31_PERMIT FILE - M2018053
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Last modified
12/19/2024 4:25:26 AM
Creation date
1/31/2019 4:16:54 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M2018053
IBM Index Class Name
Permit File
Doc Date
1/31/2019
Doc Name
Adequacy Review Response
From
Greg Lewicki & Assoc.
To
DRMS
Email Name
DMC
Media Type
D
Archive
No
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3. Please provide clarification regarding the maximum amount of area to be disturbed at any <br /> given time. Page D-10 of the application states that it will be 30 acres, page E-1 states <br /> that it will be 40 acres. <br /> Page D-10 of the application states "a total of 30 acres will be disturbed by mining at any given <br /> time." Page E-1 states "no more than 40 acres will be disturbed at any given time during mining <br /> and reclamation phases." Page L-1,the worst case reclamation scenario exhibit details that 30 <br /> acres of active mining will be open at any given time (10 acres of mining, 10 acres of pre-mine <br /> stripping, and 10 acres of post-mine reclamation)with an additional 10 acre settling pond and <br /> processing area that will require reclamation. <br /> To clarify, 30 acres will be disturbed at any given time including 10 acres of mining, 10 acres of <br /> pre-mine stripping, and 10 acres of post-mine reclamation with an additional 10 acre settling <br /> pond and processing area to total no more than 40 disturbed acres present at any given time <br /> during mining. Additionally,these acres do not include historic mine roads that will be used <br /> during reinitiated mining efforts. <br /> 4. Please provide further details regarding the use of Hyperfloc at the site. Page D-5 of the <br /> application states that only water will be used in processing gold, however, discussion <br /> regarding flocculant begins on page D-11. On page D-11 it states that the flocculant to be <br /> used will be biodegradable, however,the MSDS provided states that the product is not <br /> readily biodegradable. Please provide further details regarding the amount of flocculant <br /> to be used and its potential effects to groundwater quality and the environment. <br /> Page D-11 states the flocculant as `like Hyperfloc AF852' and is mistyped and should read <br /> `Hyperfloc AE852.' The statement made on page D-5 that only water will be used in processing <br /> gold is accurate. Flocculant will be used to accelerate the recycling process of wash water used <br /> in gold processing; therefore, no chemicals will be used in actual gold bearing gravel processing. <br /> Concentrated flocculant will be stored in secondary containment and only diluted flocculant will <br /> be found outside secondary containment and will be located exclusively within the sediment <br /> settling ponds. <br /> Page one of the included MSDS details the concentration of flocculant to be used for water and <br /> waste treatment settling/clarification at a rate of 0.5 to 20 ppm. This concentration is extremely <br /> low when compared to the full strength of the undiluted flocculant. Paragraph 4 on page two of <br /> the MSDS states that if ingested "The product is not considered toxic based on studies on <br /> laboratory animals." Paragraph 12 on page five of the MSDS lists ecotoxicity for fish, algae, and <br /> daphnia and features the hour median lethal concentration for zebra fish (96 hours), green algae <br /> (72 hours), and freshwater planktonic crustaceans (48 hours)when exposed to 100 mg/L <br /> concentrations. <br /> The highest advised waste treatment settling/clarification rate of 20 ppm is much lower than the <br /> concentration required to destroy each of the three example species over a minimum 48 hour <br /> period (100 mg/L= 100 ppm). The lowest advised waste treatment settling/clarification rate of <br /> 0.5 ppm is exponentially lower than the concentration needed to terminate the example species <br /> over a minimum 48 hour period(100 mg/L= 100 ppm). When these values are considered <br /> within a situation where diluted flocculant enters a terrestrial water system and is thus further <br />
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