Laserfiche WebLink
the groundwater compliance <br />ambient conditions defined <br />discharge. To date, we do ~ <br />2. Problem <br />values will be the same as the <br />by the quality of the Carlton <br />of have data for that poi t. <br />~dll.4 (n.C.~~-cd,2 ~7 i.t'VW.~cG.~Sc~~~c~CC.- <br />The permit directs the operator to store waste rock with >0.8~ <br />sulfur in the pits; material with <0.8~ sulfur is to be stored <br />in Arequa Gulch. I do not know how this value was determined. <br />CC&V's consultant (David Hyatt) recommended a cutoff value of <br />0.5~, but the operator disagreed with his recommendation, and <br />somehow the division accepted the Operator's recommendation, <br />making it a condition of the permit. <br />Perhaps more important, there is no established relationship <br />between the sulfur content and the values for dissolved <br />metals. <br />Solutioa <br />We will need to discuss what solution may be appropriate for <br />\ this matter. / <br />Note: <br />A considerable amount of waste rock has already been placed <br />under this condition. However, if this handling method cannot <br />be shown to be protective of the surface and groundwater, the <br />Division will need to decide what to do. I do not see how <br />this handling protocol can be shown to be protective, because <br />already it has been shown to be less than protective with <br />respect to acid generation. Metals generation is another <br />question altogether. <br />3. Problem <br />The operator has provided the Division a list of leco furnace <br />sulfur and carbon analyses of the waste rock, which the <br />operator claims that the Division required. The operator's <br />purpose in running the sulfur analyses is to determine the <br />disposition of the waste rock. However, the analyses identify <br />only the location of the rocks origins; they do not identify <br />where the waste was placed. At this point, the Division has <br />no verification of the sulfur content of waste rock in any of <br />the waste storage locations. <br />Solution <br />The operator should supply, within one week, the information <br />verifying that waste rock placed in Arequa Gulch indeed has <br />less than 0.8~ sulfur. If that cannot be provided, the <br />Operator should be considered in violation of the permit <br />3 <br />