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Stipulation No.3 <br />Page 2 <br />December 27, 2001 and June 20, 2002 samples does not represent the potential for an <br />exponential increase over time. These two samples and the June 20, 2002 sample aze <br />within the same range for pH and sulfate level showing that the change is not a trend. <br />Sunnyside believes that the current range is more within the range to be expected except <br />that pH is still artificially high. It was anticipated that pH would be azound 5.0 and sulfate <br />1,500 - 2,000 mg/1 since that is what existed prior to bulkheading. The artificially high <br />pH and low sulfate levels were created by the lime that was placed neaz the bulkhead and <br />pumped through the bulkhead. A total of 8 tons of hydrated lime was placed between the <br />bulkheads, three of which was stacked at the upstream face of the bulkhead. In addition, 1 <br />ton of hydrated lime in slurry was pumped through the bulkhead. Each time while <br />monitoring over the year since valve closure, Sunnyside purged the pipe. The water was <br />saturated with lime and gypsum, explaining the high pH and low sulfate values. It <br />appears that this slurry is now gone and the values aze approaching those expected when <br />the bulkhead was designed. These values aze well within design parameters. The <br />bulkhead was designed for very severe sulfate exposure conditions (S04>10,000 mg/1) <br />with type V cement and pozwlan. This conservative design was not because of <br />anticipated conditions, but because of the desire to assure longevity. It is unlikely that <br />with the bulkhead being in place for a yeaz and the sulfate levels and pH neaz the levels <br />anticipated upon design that exposure problems exist or will develop. <br />Based on inspections, the effectiveness of the bulkhead seal and low-pressure grouting <br />has been maximized. Leakage at the seal has been minimized but as expected when the <br />water.level rose into the fracture system, spill over started returning to the American <br />Tunnel, which is still a drain. This spill over created by the American Tunnel's ability to <br />drain the mountain will cease with placement of the .American Tunnel Bulkhead No.3. <br />While this flow return through the fractures will have to be dealt with during construction <br />of the American Tunnel No.3 Bulkhead, it is encouraging to note that water quality is <br />better than the fault water behind Bulkhead No.2. This means that Bulkhead No.2 has <br />been effective in sepazating the fault water from the neaz fracture system water which <br />was its purpose. <br />Sunnyside believes it has been demonstrated that design pressure and exposure <br />conditions will not exceed design pazameters and requests that approval be given for <br />permanent closure of the bulkhead valve on the American Tunnel No.2 Bulkhead and <br />installation of Bulkhead No.3. <br />Sunnyside also requests that DMG consider removing the monitoring stipulation for <br />Bulkhead No.3. This stipulation will delay surface reclamation by another year, <br />significantly increasing cost to Sunnyside, and is unlikely to yield any useful <br />performance evaluation because; <br />