1992-06-25_REVISION - M1988112 - Laserfiche WebLink

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Page 2 • • Mr. James C. Stevens June 25, 1992 in themselves comprise a practical moni- toring system for the containment pond and treatment facility. Given the locations proposed for Wells M-13 and M-14, should M-9 and either of the new wells have essentially the same static head, neither might be expected to readily capture timely evidence of a leak from the containment pond. The operator should commit to a re- evaluation of the proposed aonitoring network following drilling, data gathering, etc. and to add additional well locations should the existing network be determined to be inadequate. BMR Response Following the completion of the drilling, well installa- tion and data gathering activities required under the modified groundwater monitoring plan, BMR will evaluate the results of the groundwater monitoring program and assess whe#her the monitoring well network is adequate for its identified functions. BMR will provide the Division with the results of its evaluation. In the event that BMR determines that the well network is inadequate, BMR will propose additional well locations to the Division. Division Comment No. 2 As for the current locations of the wells relative to the collection pond, tailings facility and one another, the proposed network does not appear to provide the best expectation of intercepting evidence of a containment leak from the pond and facility. If groundwater flow in the area has a strong E to W component as is claimed, the breadth of potential coverage by M-1 is small as a result of its being located so close to the pond and so near a line between M-9 and the tailings facility. On the other hand. M-14 would appear to be too far from M-9 and too far southeast of the pond to be effective in monitoring for leaks from the pond, even counting on some dispersal.