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<br />- 7- <br />Please refer to original adequacy under Al`1-07 addressing the same issue. Please remove all reference <br />to 1.0 mg/I WAD CN for the underdrain discharge from the text. Please also remove the statement on <br />page 99 which states, "CN WAD concentration must be accompanied by commensurate level of the <br />Free CN." The standard was set for WAD CN not Free CN. <br />H. The operator will notify the Division immediately when the maximum head as recorded by the <br />transducers in the HVSCS in Phase I, II, and N exceeds 809c, the LVSCS or LDCRS and extemal <br />ponds is greater than 2 feet. If the condition is not temporary, CC&V must implement a plan to {ower <br />the heard immediately. <br />I. The operator has agreed to drill a groundwater monitoring well downgradient prior to application of <br />solution to [he external pond, located below the ADR building, adequate data will be provided to the <br />Division prior to application of process solution to the pond. This well will be another compliance <br />point, temporary parameters will be set until 5 quavers of data are collected. <br />The purpose of the LDCRS is to collect and recover any fluids, which might seep through the liner of <br />the pond. As in the main body of the VLF, CC&V is responsible for limiting the maximum hydraulic <br />head of pregnant solution on the LDCRS to 2 feet. However, proposal for monitoring of the maximum <br />solution hydraulic head is not presented within the text or drawings of the AM-08 application. Please <br />provide the reason why piezometers are not needed for the Phase N OLS. <br />K. GROUND WATER MONITORING (Rule 3.1.7 (7)): An operator is required to have a ground water <br />monitoring plan for an operation where an adverse impact on ground water quality may reasonably be <br />expected. The expanded Cresson Project clearly has the potential to have such an impact on ground <br />water quality in its area. The Amendment 8 application does include a proposed ground water <br />monitoring plan. However, this plan, in addition to failing to meet the requirements of Rules 3.1.7 (2), <br />(3) and (6), also fails [o meet the requirements of Rule 3.1.7 (7). The method of completing proposed <br />new wells, e.g. in Squaw Gulch and Poverty Gulch, has not been described. The frequency of reporting <br />the results of the sampling program to the Division has not been specified. Since no drilling logs or <br />geologic logs for ground water monitoring wells GVMW-8A, PGMW-IA PGMW I B, SGMW-4A, <br />SGMW-4B and WCMW-6 or for the azea of the new ADR processing pond have been included in the <br />application, the formations, aquifers or svata to be sampled at the Amendment 8 monitoring locations <br />cannot be identified. A time schedule for implementation of the missing elements of the Amendment 8 <br />monitoring plan, e.g. wells PGMW-1A, PGMW-]B, SGMW-4A, and SGMW-4B, has not been <br />provided. Finally, ambient ground water quality data sufficient to characterize potentially impacted <br />groundwater quality at the new monitoring locations in Poverty Gulch, Squaw Gulch and the area of the <br />new ADR processing pond have not been provided. <br />CC&V should fully satisfy the requirements of Rule 3.1.7 (71, i.e. supply a revised Drawino 10.1 <br />together with the missing information and materials described above. <br />L. Section 4.0 Overburden Geochemistry and following. <br />Page ?1.25 Vol. II and elsewhere. <br />The text indicates that "a total sulfur content of O.S9c was previously determined to be a cutoff <br />value below which overburden does not generate acidic leachates." This statement does not <br />displant that the 0.89c cutoff was neeotiated with the Operator to address waste handling <br />qualitatively to minimize acid generation in the AGOSA on the basis of the minimal tests <br />conductor? for Amendment '=( At the time Amendment 6 wac approved, the O.S9c cutoff ++as to <br />