2021-08-25_REVISION - M1990057 - Laserfiche WebLink

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Mr. Dustin Czapla August 24, 2021 Page 8 • The proposed amended EPP strikes out a term stating that "Prior to constructing future containment structures that will contain toxic or hazardous materials; a geological or geotechnical fracture investigation will be undertaken." (EPP § 21.8.3 at 21-16.) Applicant proposes to use and dispose of toxic and hazardous materials on the site within a few hundred feet of drinking water wells. Before a new permit is approved, Applicant should be required to undertake a fracture investigation, and a permit should not issue unless it is demonstrated that there is no risk of a fracture that could compromise the disposal pit. Due to the foregoing inadequacies,the Applicant cannot assure the protection of the Concerned Citizens' health,safety, and welfare. Therefore,the Concerned Citizens request that the Board deny the Application. If the Board elects to approve the Application, Applicant should be required to address to above listed issues before issuance of a permit. Reclamation Plan The Reclamation Plan fails to provide long-term protection against releases from the disposal pit. • The Reclamation Plan asserts that a"cyanide detoxification process"will be implemented prior to discharge of chemicals to the disposal pit. (Reclamation Plan § 5.4 at 5-4.) The Application contains no discussion of this detoxification process. Applicant should be required to provide a detailed description of the detoxification process and how this process will apply to prevent any cyanide from entering the disposal pit, including detoxification of any waste, spilled material, and contaminated objects. • The Reclamation Plan calls for a disposal pit cap consisting of 8 inches of embankment material, 4 inches of topsoil, and 4 inches of plant growth material. (Reclamation Plan § 5.4 at 5-4 to 5-5.) No minimum cap hydraulic conductivity is specified and no engineered drawings of the cap are provided. Applicant should be required to place a cap on the disposal pit that is no less permeable than the liner, as required for solid and hazardous waste facilities. (6 CCR 1007-2 § 3.5.3 (solid waste landfills); 6 CCR 1007-3 § 264.228(a)(2)(iii) (hazardous waste impoundments).) • The Reclamation Plan states that tailings in the disposal pit will be geochemically characterized prior to capping. (Id.at 5-5.) However,the Plan does not identify any criteria that must be met prior to capping. Applicant should be required to satisfy specific waste criteria, including that absence of cyanide and a neutral pH, in the disposal pit before the pit can be capped. • Applicant should be required to remove all liquids from the disposal pit prior to capping, as required for solid and hazardous waste impoundments. (6 CCR 1007-2 § 9.3.4.(F)(1)(b) (solid waste impoundments); 6 CCR 1007-3 § 264.288(a)(2)(i) (hazardous waste impoundments)). BURNS FIGA & WILL