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III IIIIIIIIIIIII III ~ <br />STAT~OF <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />t 313 Sherman St., Room 215 <br />Denver, CO 80203 <br />303 866.3567 <br />FAx: 303 832-8106 <br />DATE: June 24, 1992 <br />T0: Bruce Humphries' <br />FROM: Allen Sorenson~j , <br />OF COCO <br />~0 _ 4~ <br />~~%g <br />7 ~ n <br />~~ '~ <br />~~~ ~ 2 N, ' ~ ~,r...i ' ~s~e' i <br />fr'r'"`G's^'~ /~ y Romer, <br />~ .I ~~ Q~ liJYf(ljl v'yI~'/ Gwemor <br />~t'L, ~~ v n Z `.a f ary i./ MiOhael R. LOng, <br />G . Z ~ ~ T r Division Director <br />N <br />RE: Potential for Ground Water Impacts Due to Seepage Through ~he <br />Composite Liner Underlying the San Luis Project Tailing Po d, <br />File No. M-88-112 <br />I have completed my review of the information submitted by Rob Dore of <br />Steffen, Robetson and Kirsten (SRK) detailing the ca'c;:lations, sup rting <br />assumptions, and data used in the design of the containment system r the San <br />Luis Project's Tailings impoundment facility. Items of primary concern to the <br />Division that are addressed in the SRK memorandum are: <br />Support for the use of a permeability for "Type 2" borrow material <br />used in construction of the tailings impoundment sub-drai, age layer <br />of 5E-04 CM/SEC, and <br />Methods used in calculating the amount of seepage that may be <br />expected to escape the tailings impoundment though potent~al flaws <br />in the VLDPE liner. <br />There is a great deal of additional information presented in the SRK technical <br />memorandum but I will confine my comments to these two main points. <br />The chief factor in limiting seepage through the composite liner, is~the <br />ability of the sub-drainage layer to minimize the hydrostatic head a~plied to <br />the liner. The ability to minimize the head applied, is dependent o the <br />permeability of the drain layer material. The material specified, b~sed on <br />grain-size distribution for construction of the drain layer (Section 6.2.2, <br />Technical Specifications, Appendix J, 112 Permit Amendment, Septembe~ 1989) is <br />a compromise between a material that would provide permeability for rainage, <br />and a material that would provide filter compatibility with the tail ngs. The <br />material specified falls within the SM group of the Unified Soil <br />Classification System. Testing of material installed during construction <br />indicates that the material placed was within stipulated grain-size <br />specifications. The SRK technical memorandum states that "Based upo accepted <br />relationships for particle size for silty sand and gravel and permea iiity, <br />