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<br />BATTLE MOUNTAIN RESOURCES, SAN LUIS PROJECT <br />CMLRD ADEQUACY LETTER RESPONSES <br />Page 6 of 2B <br />The natural moisture content of the subsoils is conservatively <br />estimated at above five percent. Using methods outlined in McWhorter <br />and Nelson (1979), the specific retention is estimated to be about <br />10 percent. Therefore, the soil moisture content would have to be <br />I increased by five percent for unsaturated flow conditions to occur <br />and a seepage plume commence to migrate down to the water table. <br />Based upon the above assumptions the projected rate of permeation <br />would be 3 x 10.3 cu ft/yr/ft2 of liner. The effect of this flow rate <br />would increase the moisture content of the compacted subsoil layer <br />beneath the liner by approximately three percent over the operating <br />life of the project. <br />In addition to permeation through the liner, there is a potential <br />for flaws in the liner which could ultimately conduct flow. These <br />flaws could be formed by tears, punctures, seam defect's, etc. The <br />' estimated seepage volume through these openings will be dependent <br />upon the permeability of the underlying material, the area of the <br />opening(s), and the frequency of the openings. For analysis purposes <br />t it can be assumed that potential holes in the liner would be 10 mm~ <br />(radius = 1.78 mm) in size and would have a frequency of one hole <br />per acre. These values correspond to the EPA's evaluation performed <br />in developing the "Draft Leak Detection Rule", assuming <br />implementation of a high level quality assurance program during <br />liner installation. <br />The permeability of the subsoils beneath the liner and the applied <br />head will control the volume of seepage. For the purposes of this <br />analysis, permeability of the compacted subsoils is estimated to be <br />' approximately 1 x 10-s cm/sec. The hydraulic head which will be <br />applied to the liner will be minimized by the subdrainage layer and <br />piping. Given the permeability within the subdrainage layer, the <br />estimated head which could be applied will be about one ft. Using <br />the assumptions presented the estimated seepage through each hole <br />is approximately 5.4 x 10-~ gpm. Therefore, during final buildout at <br />an area of 167 acres (7.3 x 10"s ft2) of impoundment, the total <br />I estimated volume of seepage will be equivalent to 63.4 ft3/yr (474 <br />gallons per year). Dissipation of this flow will occur within the <br />subsoil of the site and will result in an increase in moisture <br />content of the site subsoils. Over the entire tailings area the <br />effect would increase the moisture content of the compacted subsoil <br />layer beneath the liner by significantly less than 0.01 percent <br />during operation of the project. At a specific flaw in the liner, <br />a volume of subsoil equivalent to 20 cu ft could be impacted during <br />the operating life of the project. <br /> <br /> <br />