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V <br /> AA MW Sorter <br /> c) Geologic conditions:The London Water Tunnel and the London Fault is the primary containment <br /> facility for the Site. The direction of all water to the Leadville Limestone/Dolomite formation is <br /> ordered by CDPHE since August 3, 2016, and the collection of water from that formation results <br /> in non-toxic, non-acidic water. Operation of the Lower Well (LM2.5) at flows of around 700 GPM <br /> has created a regional containment surrounding the Well so that the groundwater table is lowered <br /> nearly 1700 feet vertically (from around 12,100 feet, to near 10,400 feet AMSL) for a radius of <br /> more than 5,000 feet outward from the Lower Well. These facts were verified by the drilling <br /> investigation under the NOI (P2016-020). <br /> a. Division One(Greeley)Water Decree 8314-76 provides the following statement of facts: <br /> The London Fault is a reverse fault with considerable <br /> upthrust on the easterly portion. A fault gouge was created, which <br /> is impermeable and prevents water originating westerly of the fault <br /> from escaping through it to the east. A portion of the <br /> precipitation falling in the recharge areas enters formations <br /> dipping towards the London Fault, or generally easterly into the <br /> London Syncline. <br /> That syncline dips to the south or southeasterly. In the areas <br /> nearer London Mountain, the syncline is overlain with Belden Shale, which is <br /> essentially impervious to water. Beneath the Belden Shale is the Leadville <br /> Dolomite, sometimes called Leadville Limestone, which is highly fractured in <br /> the bottom of the syncline, particularly in close proximity to the London <br /> Fault. These fractures permit water to move down gradient from the recharge <br /> area of the London Mountain towards South Park and the Arkansas Valley <br /> They do not come to the surface for many miles, and travel for tens <br /> of thousands of years before they surface, if at all. Where the <br /> syncline crosses South Mosquito Creek, it is overlain by 600 feet of <br /> impermeable Belden Shale. The syncline can neither feed the creek nor be fed by <br /> it. The waters in the syncline are in a geologic trap, and are non-tributary <br /> waters. <br /> d) The Permittee under CDPS Permit No. CO0038334 monitors the London Water Tunnel and the <br /> discharge therefrom weekly. Under the Consent Order, the discharge Permittee also conducts <br /> monitoring of locations within and downstream of the Water Tunnel to better isolate and manage <br /> the treatment of water from the Water Tunnel. These locations include: 0210 Drift, 0205 Drift, <br /> Water Raise, Water Tunnel, Water Tunnel outfall after sediment control pond (WT001), and at <br /> SMC003 in the creek at the Site boundary downstream. Methods of sampling include weekly grab <br /> samples. Reporting is by Discharge Monitoring Reports monthly. Parameters monitored include <br /> pH, arsenic, cadmium, copper, iron, lead, manganese, mercury (quarterly), nickel, selenium, <br /> sulfide,sulfate, and zinc. <br /> e) Release response procedures include real time pH monitoring and dosing of both alcohol (for <br /> redox/ORP) and NaOH solution at the treatment location down-stream of the water infiltrating <br /> from the American Shaft area at the Water Raise within the Water Tunnel to achieve pH 8.5. Rocks <br /> throughout the London Mine are dominated by limestone so any release will not be acidic, or <br /> toxic. <br /> f) The roadway upgradient of the South London Stockpile (SLS) diverts stormwater away from the <br /> disturbance area of the SLS. Similarly,the roadway above the Central Extension and Sorting Plant <br /> stockpile diverts water away from that stockpile and from the primary processing areas. The <br /> 14 Page <br />