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2025-06-23_REVISION - M1980244 (96)
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2025-06-23_REVISION - M1980244 (96)
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Last modified
8/15/2025 9:43:37 AM
Creation date
6/24/2025 8:23:48 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1980244
IBM Index Class Name
Revision
Doc Date
6/23/2025
Doc Name
Adequacy Review Response
From
Cripple Creek & Victor Gold Mining Company
To
DRMS
Type & Sequence
AM14
Email Name
ERR
ZTT
Media Type
D
Archive
No
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Docusign Envelope ID:45B9721C-FDE2-4821-B686-80BBC79CA6DD <br /> well field could be calculated. The calculated phreatic elevation at 24 hours from a starting level of 9400 <br /> ft amsl (or 50 ft above the liner surface at the observation well) was then subtracted from the land <br /> • surface elevation, yielding the unsaturated thickness remaining between the phreatic surface and land <br /> surface. This information is displayed as a raster in Figure 65-1. It is evident that there is remaining <br /> unsaturated material along the bench face and along the 9550'bench top. The extent of the raster also <br /> corresponds to the calculated extent of the infiltration well field on the phreatic surface (outside of it <br /> there is no calculated effect). The current observation well lies outside of the calculated area of effect. <br /> 66. Please inform the Division how the results of the testing program and any necessary <br /> revisions to the design discussed in Section 6 and 7 of Appendix C.4 Hydrogeological <br /> Evaluation of VLF Leachate Injection System will be provided to the Division prior to <br /> construction of the full injection system. <br /> Data for test well flow rates and measured solution levels in the subsurface via the accompanying <br /> observation wells, will be provided in excel format following the testing. Any necessary revisions to the <br /> system will be documented and explained in a subsequent Technical Memorandum. <br /> 67. Within Appendix C.5, Drawing 810-30-01 Rich Solution Plan & Profile, a 28" pipeline is <br /> drawn along the same alignment as the four VLF2 Phase 4 solution pipes, but bypasses <br /> the collection tank and continues along the toe of the 9650 ft bench's slope. Please <br /> provide additional details of this line. <br /> Drawing 810-30-01, Rich Solution Plan & Profile, has been updated to Revision B to remove the 28" <br /> pipe in question, which was included in error. The Drawing now aligns with Drawing 810-20-01 Revision <br /> A, accurately reflecting the pipes in the area <br /> 68. Within Appendix C.5, Drawing 810-60-01 Collection Tank Layout,there are four 24" inlet <br /> flanges to receive solution from the four VLF2 Phase 4 solution pipes, however based on <br /> details provided within Appendix 1-Valley Leach Facility Expansion Design Report only <br /> • two of these pipes are 24" in size with the other two being 28". Please explain this <br /> discrepancy. <br /> The inlet flange size has been updated on Drawing 810-60-01 Revision B with two 24" and two 28" <br /> flanges to match the connecting pipes. <br /> 69. In Appendix E,the cases described through the geotechnical analysis assume a case <br /> where little to no solution is present within the ore except for residual solution near the <br /> liner. Please provide additional information regarding the choice to rely on this set of <br /> conditions, as well as an additional case that better represents conditions closer to those <br /> present during active leaching operations. <br /> The geotechnical analysis models phreatic conditions within the HLP at approximately two feet above <br /> the HDPE liner (0.5 feet above the liner was an error in the original submittal), representing a fully <br /> drained heap with minimal solution accumulation along the base geomembrane within the drain cover <br /> fill(DCF)layer. Without prescriptive criteria that define the maximum head allowed on the liner, industry <br /> practice is to keep head on the liner within the DCF layer. The calculations that were provided in <br /> Appendix C demonstrate that the average head on the liner will remain below 1.5 feet with a maximum <br /> of 1.9 feet.All four scenarios maintain the head within the 2-foot DCF layer.A system of 4-inch diameter <br /> collection pipes placed at a maximum spacing of 65-feet on center will provide sufficient drainage <br /> capacity to minimize the head on the liner. Additionally, the pads are free draining, so there will not be <br /> a constant head on the liner at the downstream toe of the facility. <br /> In response to this comment, an additional case has been modelled for each section to be more <br /> representative of active leaching operations. The additional case considers a higher phreatic surface <br /> within the heap, accounting for transient solution levels during leach cycles. The leach solution <br /> • application rate to the heap is 0.0055 gallons per minute per foot squared (gpm/sf). The hydraulic <br /> conductivity of the DCF is approximately 1.1E-01 centimeters/second (cm/s). The lower bound <br /> SSR Mining Inc. PAGE 17/19 <br />
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