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<br />' Emergency Response Plan, approved as Appendix M of CMLRB permit no. M- <br />88-112. As part of that surface water containment and remediation plan, it is <br />noted that interceptor wells may need to be installed downgradienC of the bermed <br />area within the drainage "to create a hydraulic barrier and, thus, control all <br />contaminated ground water, which would then be pumped back to the process <br />stream for detoxification". BMR believes that this concern has been addressed <br />in TR-09, as described above. <br />5. I»staliation of welts necessary to control the hydraulic gradient dmvngradient r f <br />[he tailings facility will not accomplish this contra[ in a time!}' way unless all <br />accessory equipment necessary, i.e., pumps, tubing, etc., are available. <br />BMR should commit to provide, as parr of its eventual ground water containment <br />plan, such details of well design and accessory equipment as will be installed, <br />maintained on site, ere., in older to provide assurance drat the rvclls intcrulcd for <br />use in controlling in the hydraulic gradient, dedicnted or otherwise, can lie <br />9uickly and effectively put to or converted to such use. <br />RESPONSE: BMR believes that the first paragraph of Mr. Stevens' comment is incorrect. As <br />was noted in the second phase submittal for TR-08, ground water seepage <br />velocities in this area are approximately 0.04 feet per day (14.6 fleet per year) <br />and, therefore, it is not essential that all appurtenant equipment be on site for <br />immediate installation. In addition, until a specific contaminant plume evidences <br />itself, it is not known how many wells, or at what exact locations, will be <br />necessary. However, BMR will, upon evidence of ground water cmntamination, <br />immediately move to install the necessary wells and equipment and begin the <br />ground water containment project. <br />6. Coraaminotion of unsaturated soils by surface,Jlow from the tailing.[ facility pray <br />occur, but "appropriate actions"robe taken by BMR widr the material, following <br />analysis, are not specked. <br />BMR should commit to receiving Division approval of the disposition of sucJt <br />samples before such final action is taken. <br />RESPONSE: The Emergency Response Plan addressed how BMR would respogd to surface <br />flow and what actions would be taken. BMR concurs that it will receive Division <br />approval prior to its disposition of contaminated soil. BMR acknowli'dges it may <br />also need other agency approvals prior to disposition of contaminated soil. <br />-3- <br />