Laserfiche WebLink
<br />20. Pg. D-35: "Probable maximum rainfall" criteria being used <br />by BMG is the 100 year, 24 hour storm event. This is not the <br />maximum storm than can occur in the area. The criteria must be~ <br />increased at least to the 1000 year level due to the proximity of <br />the toxic area to the town of San Luis and its aquifer. <br />21. Pg. D-37: Can the splitter embankment failure cause any <br />damage to the underlying liner system of the tailings disposal area? <br />22. Pg. D-39: The 32 acre-foot collection pond will be e <br />likely attraction for migratory water fowl. The Migratory Birc <br />Treaty Act holds that "... it shall be unlawful at any time, by any <br />means, and in any manner, to pursue, hunt, take, capture or kill... <br />any migratory bird..." The language "by any means, or in any <br />manner" has been construed by the courts to include poisoning <br />(Vencil, 1986). What steps are being taken to mitigate this <br />problem? <br />23. Pg. D-39: What is the emergency procedure should one or <br />both pumps of the pumpback system fail during an emergency~aueing <br />storm period? <br />24• [D.6.5.6] What is the emergency procedure should the <br />diversion ditches fail during an emergency, either man-made or act <br />of God? <br />25• Pg. D-42: The peak storm value of 2.90 inches of rainfall <br />in a 24 hour period is unrealistically low. The figure must be <br />raised to a more credible value. <br />26. [D.6.7.2] What is the composition of the tailings slurry? <br />What chemicals does the slurry contain, and in what concentrations? <br />27. [D.6.7.2] The tailings slurry disposal area will create <br />"free water" pools to a maximum of 50 acre-feet (covering an area of <br />20 acres or less). This constitutes an attractive landing site for <br />migratory water fowl. What procedures are planned to comply with <br />the Migratory Bird Treaty Act? (cf. question 23.) <br />28. Pg. D-59: Will the precipitation and evaporation <br />measurements become part of the public record? <br />29. The response levels for the leak detection monitoring <br />system are irresponsible. With a 192 acre tailings disposal area, <br />it is possible for BMG to maintain a leakage of 1,400,000 gallons <br />per year (of toxic solutions) without even having to report to the <br />MLRD much less do anything else about it! An even worse scenario <br />allows BMG to leak over 6,900,000 gallons per year with the oily <br />requirement being a report to MLRD. This could constitute a serious <br />contamination of the San Luis drinking water supply. The liner <br />-4- <br />