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<br />29 <br />parameter values. CC&V is proposing the PGMW-I A, SGMW-4A and ESPMW-1 be used for <br />compliance purposes along with existing wells GVMW-8A, WCMW-6, and CRMW-3B. The <br />compliance values for ESPMW-1 are suggested to he pH between 6.0 and 9.0 and WAD cyanide of 0.2 <br />mgll. VIN-tA, VlN-18, and WCMW-2 will he used as additional matutoring wells. <br />d. Rule 6.4.20 (12)r The applicant is regairod, where necessary to demonstrate that the Futvironmental <br />Protection Plan regairements are being met, to propose a water qualiry monitoring plan for both <br />surface and ground water. In company with Drawing 10.1, the application does propose a ground water <br />monitoring plan applicable forAmendtnent 8. However, this plan, as described in the application, <br />eliminates most of the current ground water monitoring wellsRocations appearing on Figure 9-! <br />together with all existing ground water permit conditions and points of compliance. The Cresson <br />Project clearly has the potential to adversely affect the qualiry of ground water i» its area where ground <br />waist has net been classified by the WgCC. Rules 3.1.7 (2). (3) and (6) require, in such case, that <br />permit conditions protective of the existing and reasonably potential future uses of the ground water <br />char may be ~rcred by rush an operation be established, included in a permit mod~eation such ar <br />Amendment 8 and that points of compliance shall ako be set, It is, therefore, the Division's position that <br />if the mare limited ground water monitoring plan proposed is to be accepted in conjunction with the <br />proposed expansion of the operation, then the existing permit conditions and points of compliance for <br />the Grassy Valley, Wilson Creek and Arequa Gulch locations should be retained In addition, (f the <br />Division determines that the ground water qualiry jusr(fs'es it, permit conditions should be established <br />and points of compliance set for Poverty Gulch, Squaw Gulch, the Vindicator Valley and the area of the <br />new A1~R processing pond <br />Re9poase: As previously indicated, CC&V will continue to monitor the existing compliance wells, WCMW-6, <br />GVMW-8A and CRMW-3E, in accordance with the limits established is Amendment No. 7. CC&V <br />proposes PGMW-l A, SGMW-4A, and ESPMW-1 for compliance purposes. The compliance limits for <br />PGMW-lA and SGMW-4A will be established once five quarters of haseline data have lrEn collected. <br />The new well to be oonstruotod doang<adieat of the Phase I, II, and III Fsternal Pond (ESPMW-t) will <br />be used to monitor the External Pond CC&V proposes that the compliance iimiu fot~ this well be a pH <br />in the range of 6,0 to 9,0 and WAD cyanido levels of 0.2 mg/l. CRMW-3B lies downgrndient of this <br />area and will contirne w serve as the full suite compliance well. CC&V is not proposing addition of a <br />compliance well in the Vindicator Valley. However, VIN-lA, VIN-18 and WCMW-2 will be usod as <br />motritoiing wells. <br />H. In the event the area is hit with a 6.0, or greater, magnitude earthquake, it could adversely t~ect the <br />VLF roe berm. !f the epicenter is located within 700 miles from the VLF, CC&V should crommii to <br />having the toe berm inspected by a register prgfessional engineer. Any damage to the toe berm must be <br />documented and a proposal for remedtation of the damage ({f any) must be submitted to the Division <br />within 30 days. <br />Response: CC& V is in agreement with these conditons based on the need to ensure structural and operational <br />atahiliry. <br />area o£the newADR nroces~in~ nand <br />