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<br /> 7/12 <br />27. Groundwater and Surface Water Baseline Study: Paragraph 2.7.3.1 references the <br />baseline water investigation in Appendix 4.5. Paragraph 7.1 (App. 4.5), Summary of <br />Findings states “Analysis of water quality data indicated the surface water and <br />groundwater on the Site has naturally occurring concentrations of constituents that <br />exceed water quality standards”. Please provide a summary table of these naturally <br />occurring exceedances. <br /> <br />Response: Table 6-1 Naturally Occurring Elevated Constituents Summary Statistics is added to <br />Section 6.2 in the Appendix 4.5 Groundwater and Surface Water Baseline Study. <br /> <br />28. Sampling and Analysis Plan: The DRMS is continuing to review the SAP (App. 4.4). <br />Should there be any comments, we will provide them before December 22, 2023. <br /> <br />Response: The December 12, 2023, PAR Part 2 for the Sampling and Analysis Plan continues <br />below. <br /> <br />A. Reporting Frequency: The frequency of reporting quarterly sampling results is not <br />defined. The DRMS recommends quarterly reporting to be no more than 30 days after <br />the end of the previous quarter. <br />• First quarter report due by May 1st of every year. <br />• Second quarter report due by August 1st of every year. <br />• Third quarter report due by November 1st of every year. <br />• Fourth quarter report due by February 1st of the following year <br /> Please provide a reporting frequency. <br /> <br />Response: In Section 2.7.4.1 Holcim commits to semi-annual monitoring in the second and <br />fourth calendar quarter of each year. Reports will be submitted by August 1 of each year and <br />February 1 of the following year. <br /> <br />B. Post Baseline Monitoring Schedule: The document only addresses monitoring as part <br />of the amendment process. What is the schedule of monitoring after the 5 quarters of <br />baseline sample collection? The Division is expecting monitoring to continue <br />throughout the life of mine. <br /> <br />Response: In Section 2.7.4.1 of the amendment application, Holcim commits to recommencing <br />semi-annual monitoring in the second calendar quarter and in the fourth calendar quarter. <br /> <br />C. Point(s) of Compliance: Point(s) of compliance (POC) well need(s) to be identified at <br />the end of the five quarters of monitoring based on groundwater flow direction across <br />the site observed during the baseline monitoring. Please commit to identifying POC <br />well(s) via the Technical Revision (TR) process within 60 days of completing the five- <br />quarter baseline monitoring program. <br /> <br />Response: Section 2.7.4.2 Point of Compliance is added to Exhibit G, committing to one POC <br />well. <br /> <br />D. Regulation 32: The specific Regulation 32 reach classification should be provided <br />along with that reach’s water quality standards table. <br /> <br />Response: The required reach classification and water quality standards table are provided in <br />Exhibit G, Section 2.7.1 of the amendment application. <br /> <br />E. Analyte List: The analyte list table should be broken into two tables, one for <br />groundwater and the other for surface water. The Division understands surface water