2022-09-23_REVISION - M2012032 - Laserfiche WebLink

Home Browse Search

DRMS Comment Text(from DRMS letter AR Round 2) OSMI Responses Comment# On Page U-37 section 10.1.1"A proposed new sediment pond will capture stormwater to infiltrate groundwater."OSMI agrees that the proposed Sediment Pond##2 meets the definition of an EPF because it is designed to capture The Division infers this to be regarding the new stormwater pond located near the entrance to the site depicted runoff from the mill area where reagents are transported and stored. It has been designed to contain the 10-year 58 on Map U-1. If so please provide more information including design specifications, drawings and estimated 24-hour storm event.A discussion of this feature was added to Section 2.S of Exhibit U and added to Map U-1. construction schedule.Please note that this pond,like all other stormwater control features,will be considered an P.E.-certified designs of the sediment pond H2 are included in updated Appendix 2,which is located in Attachment EPF and subject to all applicable Rules.Ensure that all other exhibits are updated to reflect this new feature. 2 of these responses to comments. Table U-11 provides Surface Water Sampling Results.Additional samples that do not correlate to those listed on OSMI uses a robust sampling and analysis program for its surface water and groundwater sampling to ensure the map U-1 were provided.Please clarify specifically for samples SW-0 and SW-99 what/where these locations are. data are reliable and precise.SW-00 and SW-99 represent field blanks and field duplicates,respectively.The S9 location of where a duplicate is collected changes with each monitoring event so as to evaluate data reliability at various locations.A blank is typically collected at the end of a sampling event.A description of SW-00 and SW-99 were added to Table U-10. Page U-46 section 12.2 references table U-8,this should be table U-10.Please update table reference. The incorrect reference to Table U-8 has been updated to Table U-10 in Exhibit U.See updated Section 11(not 12) 60 in Exhibit U for details. No revised exhibit was submitted,only tahle responses.Please incorporate changes specified in the PAR response OSMI did not provide an updated Geotechnical Exhibit because there were no changes made to the actual exhibit table into the exhibit language as appropriate and submit the revised Exhibit. as a result of OSMI's responses.Rather,the information contained in the Geotechnical Exhibit was used to 61 address DRMS comments and to update other exhibits such as Exhibit D.Nonetheless,a discussion of OSMI's responses to comments were added to the cover sheet for the Geotechnical Exhibit.See Attachment 1,Updated Exhibits for details. general No revised exhibit was submitted,only table responses.Please incorporate changes specified in the PAR response A revised copy of the SPCC Plan is provided in Attachment 6.The updated plan addresses comments 61 through comment table into the exhibit language as appropriate and submit the revised Exhibit. 63. (no number) SPCC table on page 24 does not include containers C-10 and C-11.Please revise the table to include all applicable See updated SPCC Plan in Attachment 6. 62 containers. 63 Update the SPCC to reflect that the Material Warehouse Buildings has replaced the Material Storage Conex as See Updated SPCC plan in Attachment 6. storage location C-3. The interpretation of Rule 6.4.21(10)(a)is incorrect.Section ii of this Rule identifies features intended to convey,As was discussed with DRMS,OSMI will treat the stormwater diversion channels as EPFs.A description of the transport or divert surface water around or away from acid mine drainage or toxic or acid forming materials as original designs and location of as-built certifications is provided in updated Exhibit G.These features are also EPF's.By this definition,that includes features and(Best Management Practices)BMPs which mitigate or control described in updated Exhibit U.Engineering designs for these features are provided in Updated Exhibit G and run-on-water.The Division requires these EPFs to be designed and certified by a licensed professional engineer in Appendix 2,which are located in Attachment 1 and 2,respectively. accordance with the Rules.Please provide the required information for all Stormwater control features. Although OSMI is agreeing to add this information in the exhibits,we do not agree with DRMS's interpretation of the rule.Rule 6.4.21(10)(a)specifically refers to EPFs intended to convey,transport,or divert surface water around or away from acid mine drainage or toxic or acid-forming material.EPF is a defined term under Rule 64 1.1(21)and"means a structure which is identified in the EPP as designed,constructed and operated for control or containment of designated chemicals,uranium,uranium by-products,or other radionuclides,acid mine drainage, or toxic or acid-forming materials that will be exposed or disturbed as a result of mining or reclamation operations." Stormwater run-on diversion ditches in this case do not meet the definition of an EPF as they are not designed,constructed or operated to control or contain designated chemicals. Specifically run-on control and diversion ditches are designed to convey unimpacted stormwater that has not come into contact with designated chemicals or other acid drainage or acid-forming materials. OSMI agrees that stormwater features used to convey stormwater associated with an industrial activity that may come into contact with designated chemicals and acid forming materials would be considered part of an EPF. Amendment 02 AR Responses Round 2 M-2012-032 7of8