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<br />Letter to J.J. Jones -3- August 27, 1996 <br />monitoring program. <br />In order to resolve the question of monitoring parameters for the ground <br />water well at the Henderson Mine, the Division suggests that CMC collect <br />a representative sample of untreated mine water, and subject that sample <br />to analyses for a full suite of potential contaminants using analytical <br />methods sufficiently sensitive to detect contaminants at the most <br />restrictive applicable standard, including aquatic life standards. <br />Required detection limits for certain critical parameters are provided <br />here: <br />Arsenic - 0.01 mg/L <br />Cadmium - 0.0003 mg/L <br />Copper - 0.005 mg/L <br />Lead - 0.005 mg/L <br />Selenium - 0.01 mg/L <br />Silver - 0.0002 mg/L <br />Any questions regarding required detection limits for the other parameters <br />should be directed to the Division. Any potential contaminants, other <br />than a core group of critical indicator parameters, that are found to be <br />non-detectable in this screening analysis would be dropped from the <br />analyte list. Contaminants that are detected would be included in the <br />analyte list for monitoring of the point of compliance well until the <br />Division is satisfied that representative samples have been collected for <br />both a high water table and a low water table condition. At that time, <br />any parameters that are found to be non-detectable, other than a core <br />group of indicator parameters, would be dropped from the analyte list. <br />The same procedure would be followed at the mill site, except that there <br />will be two or three wells being monitored instead of one, and the initial <br />screening for contaminants would be done using a representative sample of <br />raw seep water from the tailing impoundment. <br />2. Numeric Protection Levels for Ground Water <br />Since CMC and the Division have reached an impasse regarding the <br />application of numeric protection levels for ground water at the Henderson <br />Mine and Mill, the Division is taking CMC's position on this issue under <br />advisement, and will contact CMC once a course of action to resolve the <br />impasse has been developed. This will probably not occur until early in <br />November, 1996. <br />3. Ground Water Monitoring of the Precambrian Basement Rock <br />CMC has grouped ground water units at the Henderson Mill tailing site on <br />the basis of geology, and has identified two basic units. The upper unit <br />consists of the Troublesome Formation, glacial till, and alluvial <br />material. The lower unit consists of precambrian basement rock. The <br />Division and CMC have agreed that the upper ground water unit may be <br />