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r • , <br />one day afrer replacement, and have remained inoperable through the end of the report period, <br />July 3, 1995. I do not believe it acceptable for both transducers to be out of commission <br />simultaneously. This makes it impossible for CC&VG to monitor the hydrostatic head within <br />the LVSCS, which is required to be maintained below 2 feet. I realize that unanticipated events <br />happen. However, repair or replacement should be possible within five days. IF CC&VG needs <br />to redesign the monitoring system it should. In the interim they should stockpile spare <br />transducers to expedite replacement in the event of failure. I recommend that we inform <br />CC&VG that in the future the Division will issue a reason to believe notice if both transducers <br />are inoperable simultaneously for a period in excess of five days. <br />LVSCS <br />CC&VG initiated pumping fluids from the LVSCS in early January of 1995. CC&VG records <br />the cumulative metered volume of fluids pumped from the LVSCS. This data allows the <br />calculation of daily fluid volume pumped from the LVSCS. If we assume that the two pumps <br />were pumped until cavitating each day, this information represents the volume of fluid leaking <br />into the LVSCS each day. Upon comparison with the updated information regarding action <br />leakage rates provided by CC&VG, this allows us to determine which action level CC&VG <br />currently occupies. The data suggests that leakage initiated in early January. The me of <br />leakage accelerated significantly when the fluid level rose above 26 feet in the pregnant solution <br />storage area, reaching a maximum of 7.75 gpm on February 22, 1995. CC&VG then began to <br />lower the pregnant solution level in an effort to reduce the leakage rate. As the fluid level <br />decreased below 20 feet on February 25, the leakage rate began declining. As CC&VG <br />maintained the pregnant solution fluid level between 19' and 24' through March 11, 1995, the <br />leakage rate dropped to a low of 0.75 gpm and then rebounded, varying to as high as 2.0 gpm. <br />On March 22, 1995, CC&VG began raising the pregnant solution fluid level, reaching an <br />apparent maximum of 28.5' on June 21, 1995, during which daily leakage rates into the LVSCS <br />varied between 1.3 gpm and 7.15 gpm (June 22, 1995). Because of unreliable or nonexistent <br />transducer control the later periods monitoring data may be questionable. However, in general <br />the leakage rates experienced during the second rise in the pregnant solution pool do not appear <br />as dramatic as those of the fast level increase. This would suggest that the leaks have partially <br />healed. However, the daily data is not conclusive, because of the questionable control on the <br />pumping of the sump due to the transducer failure. <br />Throughout much of the brief history of the partially completed Phase 1 liner, CC&VG has been <br />operating within the "above 2 percent exceedence" or "10 percent to 2 percent exceedence" <br />response levels or ALR's. Once the transducers have been replaced we should revisit the <br />monitoring data with CC&VG in order to render the data more useful and to assist them to <br />perfect their reporting and analysis methodology. <br />LDS <br />Several of the leak detection sumps (LDS) began expressing fluid during this spring. LDS-03 <br />began on March 18, 1995, LDS-02 began on May 4, 1995, and LDS-OS began on January 10, <br />1995. Generally summarized, in each case the flow rate and WAD cyanide concentration <br />reached a maximum during~lte wet spring and have since declined. In addition, in each case, <br />