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<br /> <br />Memo to James A. Pendleton 2 July 6, 1992 <br />If the Quality AssurancefQuality Controls Protocols cover frequency of sampling <br />and analysis of cyanide under such circumstances, a more specific reference <br />should be provided. Otherwise, a sampling frequency and cyanide analysis should <br />be indicated. BMR should also commit to continuation of such sampling and <br />analysis until the Division releases them from the requirement. <br />4. The positions of the approved ground water containment well series will be fixed, <br />presumably within a few hundred feet of the tailings facilities. It is conceivable <br />that a substantial surface release of cyanide-laden water from the facilities, <br />following the local drainage, might carry beyond the influence of the approved <br />ground water containment wells before infiltrating and percolating to the level of <br />local ground water. Nothing in the proposal, as presented, considers and evalu- <br />ates the possibility of such an event or proposes any appropriate interception <br />and/or containment measures. <br />BMR should develop and include, as part of this technical revision, an evaluation <br />of this possibility and a description of what, if any, measures would be necessary <br />and taken to deal with such a situation. <br />5. Installation of wells necessary to control the hydraulic gradient down radient of <br />the tailings facility will not accomplish this control in a timely way u~ess all <br />accessory equipment necessary, i.e., pumps, tubing, etc., are available. <br />BMR should commit to provide, as part of its eventual ground water containment <br />plan, such details of well design and accessory equipment as will be itistalled, <br />maintained on site, etc., in order to provide assurance that the wells iptended for <br />use in controlling the hydraulic gradient, dedicated or otherwise, can be quickly <br />and effectively put to or converted to such use. <br />6. Contamination of unsaturated soils by surface flow from the failings facility may <br />occur but "appropriate actions" to be taken by BMR with the material, following <br />analysis, are not specified. <br />BMR should commit to receiving Division approval of the disposition of such <br />samples before such final action is taken. <br />JCS/bjw <br />M:'~OSS jbjw/Memo.JCS <br />