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2023-07-28_REVISION - M1977170 (2)
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2023-07-28_REVISION - M1977170 (2)
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Last modified
7/31/2023 2:35:53 PM
Creation date
7/31/2023 1:14:13 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977170
IBM Index Class Name
Revision
Doc Date
7/28/2023
Doc Name
Adequacy Review Response
From
Butala Construction Company/Pinyon Environmental Inc
To
DRMS
Type & Sequence
TR3
Email Name
LJW
THM
Media Type
C
Archive
No
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COC, as well as the laboratory's reliable detection limits (RDLs), and minimum detection limits (MDLs) based <br /> on selected laboratory methods.The project laboratory to be used is Origins Laboratory, Inc. (Origins), located <br /> in Denver, Colorado and their sub-lab,Waypoint Analytical, LLC (Waypoint), located in Memphis, Tennessee. <br /> Sampling Rationale <br /> The spatial beundaFies aFe the e)Etents ef sand and gFayel FnateFial mined, pFeEessed, and Ste&piled en site. <br /> Initially, Pinyen Staff will EUFFent SteEkpiles at the BUtala faEility. The Ste&pile IeEatieHS will be <br /> estimated quaRtity (EubiE YaFds, yd3) will be deEHFnented. The estimated quantity will be eyaluated using the <br /> *ndustr-y standffd Fnetheds. MateFial that has been impeFted te the Fnine fFeFn aH eff site SeUFEe, will be <br /> deEHFnented, but net sampled and will be assumed te be nen *FnPaEt__ <br /> The spatial boundaries are the extents of sampleable sand and gravel materials mined, processed,and placed in <br /> final, ready to be sold stockpiles on-site. The current sampleable stockpile locations, identification numbers, <br /> and volumes,for material produced on-site, are provided on Figure I. In addition,there are various small piles <br /> of materials such as surge piles from the processing plant, materials staged to top off trucks, and materials that <br /> have been washed. These piles are depicted on Figure 2. The material volumes were estimated using recently <br /> collected aerial photogrammetry and LiDAR data. These piles will be sampled as follows: <br /> • Surge piles contain materials dropping off of conveyers from the plant. These materials are collected and <br /> moved to stockpiles. The materials in the surge piles are I inch or greater. Therefore,the current surge <br /> piles will be inspected to determine whether creosote is present, but samples will not be collected. <br /> • Small piles maintained for topping off trucks will be visually inspected if the materials are greater than I <br /> inch. For small materials, one composite sample will be collected from each pile or bin. <br /> • The crushed slag piles have been in place for 25 or more years, are consistent in size to historical satellite <br /> imagery, and visibly are distinctly different material than the gravels and sands. Therefore, it is clear that <br /> Mine Restricted Area materials were not moved to these locations and no samples will be collected from <br /> these piles. <br /> • There are several material stockpiles that have been imported to the Mine from an off-site source. Those <br /> material locations and volumes are provided on Figure 2. These imported materials are assumed to be <br /> free of creosote, and will not be sampled. <br /> • A small amount of sediment removed from settling ponds also is located on site. This material will not be <br /> sampled. <br /> Field observations for creosote staining will be made. If creosote staining is identified, no samples will be <br /> collected, and the stockpile will be assumed impacted. <br /> If no creosote staining is observed, composite samples will be <br /> collected in 4-ounce wide mouth glass jars,which have an opening diameter of approximately 1.75 inches. The <br /> material must be small enough to allow collection of a representative sample using this sample container. If the <br /> FnateFial Will net fit in the sample jaF,the YiSHal EFeesete staining ebser-yatiens will be used te eyaluate whetheF <br /> Most of the material that will not fit in the sample jar has already been visually <br /> evaluated and those results were provided under separate cover. The on-site produced materials that will be <br /> sampled versus those that are too large for the sample containers are identified on Figure 1. <br /> Mr. Lucas West Page 3 <br /> Environmental Protection Specialist <br />
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