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2020-08-07_REVISION - M1980244 (9)
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2020-08-07_REVISION - M1980244 (9)
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Entry Properties
Last modified
12/27/2024 11:55:29 PM
Creation date
8/13/2020 6:45:30 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1980244
IBM Index Class Name
REVISION
Doc Date
8/7/2020
Doc Name Note
Vol 1 of 2
Doc Name
Adequacy Review Response
From
CC&V
To
DRMS
Type & Sequence
AM13
Email Name
TC1
JPL
ERR
BFB
MAC
Media Type
D
Archive
No
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NEWMONT 14e wncr,rN r,g r ,rat <br /> 125 feet off iII(compromising mill integrity)or the vibration causing wear on the SGVLF liner leading <br /> to leakage. As such,the certification report was required for the mill platform(also considered an <br /> EPF as its construction and performance was and is critical to the two EPFs it supports <br /> performance). Therefore, regardless of how Newmont has interpreted the acceptance of the Mill <br /> Platform certification report, the HGM liner was never considered an EPF, but only tertiary <br /> containment." The Division asked Newnwnt personnel at the time if then wanted an official letter <br /> from the Division outlining the reasons why the HGAI liner could not be accepted as an EPF As no <br /> request was made, the Division considered the mutter settled As additional background, the <br /> description of the HGAI liner in the AAA 10 text stated it drained to the SGVTF VLF2 liner and only <br /> one cross-section of the liner system Was presented in the permit level design drawings. The Division <br /> assumed bused on the text, that the liner system was free-draining in the direction perpendicular <br /> to the provided cross-section. Furthermore,.4ngloGold.-lshanti did not request can EPF designation <br /> for the HGAI liner. The Division interpreted the design to he tertiary containment as AngloGold <br /> Ashanti was well aware that EPF liner.systems that impound water were required to be triple-lined <br /> and have leak detection systems. The Division cannot accept the HGzV1 liner cis an EPF,for the <br /> .following reasons: A) It is only a dual liner (soil liner fill and LLDPE geomemhrane), where EPF.s <br /> designed to impound water that rnav contain designated chemicals, and or toxic or potential1v acid <br /> generating material(in this case up to approximately.six feet before it spills over the SGb"LF VLF? <br /> liner system)must he triple lined: and B) There is no leak detection system under the HGAI liner <br /> necessan, to monitor the liner for potential leakage, as required were it an EPF. The Division <br /> requires the HGAI liner be removed from Table U-2 or CC&V must provide construction level <br /> designs and specifications showing how the HGM liner could be retro-fitted to meet the <br /> requirements of'an EPF. <br /> Newmont Response: <br /> CC&V appreciates the history provided by DRMS in its response, however, CC&V respectfully disagrees <br /> with DRMS' assessment as it does not clearly identify a deficiency that would prevent the Mill Liner from <br /> meeting the Environmental Protection Facility Requirements, as required by the Rules. If such a <br /> deficiency exists, CC&V requests DRMS to indicate which Rule(s)the Mill Liner fails to satisfy. <br /> DRMS Comment(italics): <br /> J_. Table U-?,p. 10, Environmental Protection Facilities. The table lists only four EPF.s and the HGH <br /> Liner is erroneously included(see Comment 56). The Division considers the fbllow•ing.facilities to <br /> he EPF.s: <br /> a. Carlton Adsorption,Desorption Recovery(ADRI), <br /> b. Squaw Gulch ADR (ADR?), <br /> c. Enrichment Circuit (Carlton) &Assay Lahoratorv, <br /> d High Grade Alill(not the liner), <br /> e. Process Solution Enhancement (PSE), <br /> f. AG VLF VLF1 (including the leak detection.system), <br />
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