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<br />K. GI1O~D WATER MONITORING (Rule 3.1.7 (7)): An operator is required to have a ground water
<br />monitoring pplan for an operation where an adverse impact on ground water quality may rearonahly be
<br />expected.; Th,eexpanded Cresson Project clearly htrs the potendiad to have such an impact on ground water
<br />quality in its ar~q. The Amendment 8 application does include a proposed ground water monitoringplan.
<br />however, this`plan, in addition totalling to ineet the requirements of Rules 3.1.7 (Z), (3) And (ti), also fails to
<br />meee the requirements of Rule 3.1.7 (7). The +nethod of completiog proposed new wells, e.g. in squaw Gulch
<br />and Poverty Gulch, has not been described. The frequency of reporting the results of the sampling program to
<br />the Division has not been specified. Since no drilling lags or geologic logs for ground water monitoring wells
<br />GVMW-8A, PGeGIK! lA PGMW 1B, SGMW-4A, SGMYI~ 4B and GVCMW-6 arfor the at'ea of the newADR
<br />prncessingponr!bave been included to the application, theformations, aquifers orstrata to be sa+npled at the
<br />Amendmen! B. riionitartng locations cannot be identified. A time schedule for implementation of the missing
<br />elements of theAmendment 8 monitoringplan, e.g. wells PGMW-l A, PGMW-IB, SGMW-4A, and SGMW:4B,
<br />has not been provided. Finally, ambient ground water quality data su~cient to characterize potentially
<br />impacted groundwater quality at the new monitoring locations in Poverty Gulch, Squaw Gulch and the area of
<br />the new ADlt pracecstng pond have not been provider!.
<br />Response: %Drawing 10.1 has been revised (Attachment 8) to show the locations of the above referenced wells
<br />which uvere not previously included, GVMW-8A and WCMW-6 as well as the proposed location for the
<br />new monitoring well downgradient of the Phase I, II and IiI &xtemal Pond. The drawing has also been
<br />revised?to include WCMW-2. Attachment 9 includes well logs for GVMW-SA, PGMW-1 A, PGMW-
<br />.. 1B, 3QMW-4A, 3GMW-4H, WCMW-6, and WCMW-2. The well log for compliance wall CRMW-3D
<br />was previously included in Amendment No. 7, but is also being included in Attachment 9 for ease of
<br />reference. Atypical well completion diagram is included in this attachment for the new well to be
<br />drilled downgradient of the Phase I, Tl, and III External Pond.
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<br />CC&V. is proposing to collect ground water quality samples from the new wells (PGMW-lA, PGMW-
<br />1B, SGMW-4A, SGMW-4B and the Phase I, II, and IIT External Pond well) over the next five quartets
<br />in order to better deftne background conditions for these wells. CC&V is proposinP that PGMW-lA
<br />and SGMW-4A be used as compliance wells. After five quarters of data aze collected from these wells,
<br />CC&Y;will submit this information to the OMIJR along with proposed limits for pH, WAD cyanide,
<br />zinc, ijtanganese and sulfate. In addition, the Phase I, II, and-III Extemal Pond well, designated as
<br />ESRM-'W-1, well have limits of 6.0 to 9.0 for pH and WAD cyanide of 0.2 mgll. Ground water quality
<br />monitoring wells GVMW-SA, WCMW-6 and CRMW-3B will continue as compliance wells in
<br />-~ AmettdmentNo.8.
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<br />L. Section 4,O Overburden Geochemistry and fallowing.
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<br />1. ~ Page Zl, ZS Vol. II and elsewhere.
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<br />• ~ il; The text indicates that "a total suer content of 0.8% was previously determined to be a cutoff
<br />c o value below which overburden does not generate aeidio leaohates. " This stet®ment does not
<br />-s. drsp/ant that the 0.8% cutoff was negotiated with the Operator to address waste handling
<br />'; gualitativedy to minimize acid generation to the AODSA on the basis of the minimal tests
<br />=:: conducted forAmendment #6. At the time Amendment 6 was approved, the 0.8% cutoff was to
<br />.x be an interim measure for waste rock control, field results from which were to have provided
<br />-; information ors the possible need for overburden capping in the past-mining setting. Whether
<br />the 0.8% Spresumptton was used in calcudations of overall NNP predictions is not evidentfrom
<br />:q; the text.
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