1992-11-19_REVISION - M1980244 - Laserfiche WebLink

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4' Mr. Edgar Hunter 5 November 19, 1992 V. Geochemistrv and Hvdr2chemistrv The Division feels that the amendment contains an insufficient quantity of testing information on geochemistry. The X-Ray diffraction scans included in the report are not documentable in their present form; they contain almost no information that should be considered far routine DA/QC (quality assurance, quality control) such as sample number, rate scan, identifying standards, operator, or date of analysis. Furthermore, these scans identify only the major minerals: quartz, sanidine and clay. The Division requests that the operator fully identify the composition of the ore and waste rock using quantitative mineralogical analysis. The existing XRD studies are not adequate. The Division also requests that the operator include leaching studies of the ore and waste to identify the conditions that will exist, especially aher the operation is reclaimed. It is especially necessary to properly document that any rack used in the underdrain -including but not limited to the bedrock that may be explored -have adequate analytical information to predict future acidity, leachability and metals concentrations. The documentation should provide all leach test results and identify all of the assumptions inherent in each test. VI. Exhibit G Water Information 11 The Division requires that the operator provide at least four quarters of baseline information for both ground and surface water with a complete suite analysis. The information provided in Exhibit G is inadequate; therefore, the Division, as agreed during the pre-application meeting, will stipulate that this information be provided before the leaching process starts. 2) The operator states under Exhibit G "b" that the portions of the rule under letter Ib) are not applicable. The Mineral Rules and Regulations states that "if the operation is not expected to directly affect surface or ground water systems, a statement of that expectation shall be submitted." The operator states that because it is a closed system it will have no impact on the surface or ground water. The Division understands the system, and i1 is far from being a closed system even though the operator is attempting to take adequate measures to assure that the operation will not impact the hydrologic balance. Tha only true closed system of the operation are the ponds. The Division requests the operator to submit, in accordance with the Mineral Rules and Regulations, water information that applies to the entire permit area. The information should address applicable aspects of Rule 34-32-1 1 6 17)(a)Ib)(clld)(e)(f)Ig)(h)(i) should be included in the report. 3) The water balance information provided by the operator assumes the 100- year, 24-hour ppt. event to be 3.5 inches. These assumptions were also used by the Vector Engineering Study in their design for the ponds and diversion ditches. The 100-year, 24-hour ppt. event for the area is 4.5 inches, NOAA 1973. Please provide a detailed water balance using the 4.5