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5~~ D1. Qa lerlc $ Zi+S 985 5557 SRh DENVER 6' <br /> • <br />6AT'1CE MOUNTAIN RESOURCES, SAN LU[S PROJECT <br />CMLkU ADCQUACY LETTER RFSPONSCS <br />Page 5 of 28 <br />The data presented in Attachment 1 also demonstrate that no changes <br />in metal concentratio~ls and acidity have occurred as a result of the <br />change in processing. <br />10. Please :ommit to achieving 1x70'6 cm/sec permeability for the <br />underlying colluvfal material after tt has been compacted to 95% <br />maximum Proctor density. It wi )1 be necessary to provide ~~erification <br />to the Division that this permeability has been achieved prior to <br />installation of the VLDP£. <br />^i.;PG~;Sc: Because of the nature of the underlying colluvfal materials, it is <br />r.ot possible to achieve a uniform 1x10-6 cm/sec permeability after <br />the material has been compacted to a 95% maximum Procl.or density. <br />The combination of the law permeability tailing:• following <br />deposition, the drainage layer's ability to reduce hydraulic head <br />on the geosynthetic liner and the function of both the geosyntfietic <br />liner and compacted soils to limit potential seepage eliminates the <br />potential requirement for a lower permeability of the compacted <br />subsoil. Seepaye potential ;s discussed in the response to guestian <br />11. BMR can achieve and will commit to achieving a 1110- cm/sec <br />permeability in the colluvfal materials following compa~:tion and to <br />perform material testing during construction to confirm tiese values. <br />Please provide a detailed discussion regarding the pote~ntia) for a <br />detection of leakage from the VLDPE liner to the underlyi,g colluvfal <br />materials. A rationale for the placarnent of the monitcring wells, <br />includfng the potentfal for those wells fo intercept leakage from <br />the tailings faciilty, should be included. <br />Qot^_ntial leakage through the VLDPE liner could occur via two <br />~Jifferent pathways; seepage via permeation through the liner itself <br />:nd through flaws in the liner. Seepage through the liner itself will <br />:~: controlled by the thickness of the liner, the head cn the liner <br />and the permeability of,~he liner. For the VLDPE liner are equivalent <br />permeability of 1 x 10-` cm/sec (manufacturer's literature) can be <br />asswned. <br />If permeation occurs from the base of the liner, the flu ds will not <br />immediately migrate to the groundwater. The underlying a1'iuvial soils <br />at the project are unsaturated and at a moisture content <br />significantly less than the specific retention of the material. <br />Specific retention is defined as the moisture content above which <br />gravity flow through the soil will occur. In general, the groundwater <br />averages about 150-ft below the surface. <br />r.j <br />__.. <br />