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• • <br />All liners allow water movement, although HDPE liners under ideal conditions <br />allow minor leakage. Leakage is due to water vapor movement or leaks, and <br />over a large area (such as the 7 acre waste pond), minor leakage results in gpad <br />results. The WQCD regulation, rule 6.15.9 provides for allowable seepage of up <br />to 1X10 to -6 cm/sec or 924 gpad. Therefore, WRN asked for a waiver of the <br />WQCD requirement for• a Ground Water Discharge Permit. The first liner met <br />(and still does), the ma:~imum allowable limit from the WQCD. The second <br />liner allows collection of leachate, and pumping the leachate back to the ponds. <br />An expanded plastic filler between the liners allows drainage to a central point <br />for pumpage back to the ponds. Frequent pumpage reduces the chance of <br />leachate movement through the second liner and maintains minimal head <br />pressure on the second liner which minimizes water vapor movement. <br />The ponds contain more water recently, than at any time in the past. Therefore <br />the head pressure is greater. In order to reduce chance of leakage the frequency <br />of pumpage has beennrcreased. A sprinkler system has been purchased to <br />reduce the volume of water in the waste pond. Also, WRN is in the process of <br />installation of a system to circulate warm water from the facility to the waste <br />pond to increase pond water temperature and increase evaporation. The water <br />from the waste pond will be circulated in a loop with no net increase in volume. <br />Cool water from the waste pond will be used to cool the pregnant liquor stream. <br />The sprinkler system and increased temperature in the waste pond will consume <br />more water and allow reduced volumes. Operational changes are planned to <br />reduce the volume of water in the process pond. Currently, water can be <br />recycled from the process pond to the facility and WRN plans to reduce the <br />pond volume. <br />After a review of DMCi rule 3.1.7 (1), (2), (3), {4), (5), (6), and (7), WRN <br />believes a monitoring program, points of compliance, permit conditions, and a <br />Technical Revision is not warranted at this time. Section 3.1.7(2) states <br />"Pursuant to the procedures specified in Paragraph 3.1.7(3), permit conditions <br />shall be established for each operation that may have a reasonable potential to <br />adversely affect the quality of a specified area that has not been classified by the <br />WQCC." Also, for existing operations, Section 3.1.7(3}(b} states "Upon a <br />determination that a violation of a permit provision affecting groundwater <br />quality has occurred, ttie Board may order the Operator to submit an application <br />to modify the permit to comply with Paragraph 3.1.7(2), and may set a <br />reasonable schedule for submittal of such an application." Also under Section <br />3.1.7(3)(b)(ii), "Such enforcement action may result in a finding of a violation of <br />