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Groundwater wells should be sampled initially for the following: <br /> pH TDS Al Fe Se Bill <br /> Conductivity SO4 As Pb Ag <br /> Major cations Chloride Ba Mn Na <br /> Major anions Nitrate Bo Hg Zn <br /> Alkalinity Nitrite Cd Mo <br /> Hardness Ammonia Cr Ni <br /> WAD CN <br /> Detection levels should be low enough to detect whatever amount would be regulated for surface <br /> water at a low hardness Of local surface water hardness is not known, I would recommend assuming <br /> an equivalent hardness of 100 mg/L as CaCO3.) Detection levels for most of the metals will be <br /> sufficient if analyzed by ICP. However, other methods will need to be employed for Cd, Cu, Pb, <br /> Hg and Ag. A chart of the standards was furnished to you earlier. <br /> Monitoring: surface water. <br /> Surface waters should be collected on the same frequencies, and analyzed for the same parameters. <br /> Collection points should include at least two points in the diversion ditch (to assure that the road <br /> or other sources have not contaminated the ditch), the station above the mill tailings and above the <br /> diversion ditch (Station 31), and the station below the tails (preferably Station 24). <br /> It is not evident in the data that groundwater from the site gets collected at Station 22, so I might <br /> recommend that it not be sampled. If a low-flow station is needed downstream, you should collect <br /> below station 24. <br /> Reclamation. <br /> As the above report indicates, this operation appears not to be minimizing impacts to the hydrologic <br /> balance, either to surface water or groundwater. Part of the metal and acid load is certainly coming <br /> from pre-law tailings, but part also appears to be coming from the new tailings as well. As time <br /> goes on, it is likely that the rate of oxidation (weathering) will increase, and the new tailings will <br /> become more of a problem. Given this situation, the recommendations for reclamation deal more <br /> with an overall reclamation scheme than the scheme that is currently provided in the permit. <br /> Ideal reclamation of the tailings would require sealing the tails from water and oxygen in order to <br /> minimize the rate of weathering. If most of the tails are to be reclaimed in place, the best that could <br /> be done would be to stack as much of the tailings as possible into a single pile, cap the pile, and <br /> provide an upland diversion. Also, the rate of groundwater flow into and out of the base of that <br /> pile should be reduced by some means. <br /> Before more tails are added to this operation, the tailings ponds should be properly lined and <br /> protected from erosion and deterioration. <br /> 5 <br />