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1992-10-19_REVISION - M1988112 (5)
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1992-10-19_REVISION - M1988112 (5)
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Last modified
6/20/2021 5:59:48 AM
Creation date
11/21/2007 9:18:46 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1988112
IBM Index Class Name
Revision
Doc Date
10/19/1992
Doc Name
ADEQUACY RESPONSES TO ADEQUACY COMMENTS TO TR8 PHASE II SUBMITTAL EXISTING GROUND WATER MONITORING
Type & Sequence
TR8
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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<br />CMLRD reporting the results front the additional drilling, testing attd rttodellirtg." <br />As such, BMR has already agreed to submit the documentation faom the second <br />phase to the CDMG, which was done on August 6, 1992 (in a report entitled <br />"Modijicatio»s of E>•isting Ground Water Monita•irtg System, Smt Luis Gold <br />Project, Costilla Coterrty, Colorado "). <br />3. 77tere is no frequency specked for the proposed sampling of the pump discharge <br />from the ground water cwttainmerrt wells in corjunctiwt tvitl: a ground water <br />remediation program. 77rere is no indication of which forms of cyanide would be <br />determined. <br />If the Quality Assurance/Quality Control Prntncols cover fr•equerrcy of sarrrpling <br />and mralysis of cyanide under such circeonslances, amore speck reference <br />should be provided. Otlrenvise, a sampling frequency and cyanide analysis <br />should be indicated. BMR should also conrrnit to cnntirrunnon of such sarrrpling <br />and analysis until the Division releases [bent front the requirement. <br />RESPONSE: In the event that a ground water containment program woulkl need to be <br />implemented, required sampling frequency would be developed on asite-specific <br />basis. This proposed sampling frequency would be submitted to Uhe CDMG for <br />its review and approval prior to implementation. To establish the frequency at <br />this time could not take into account the magnitude or the scope o~ any potential <br />containment program. BMR would propose establishing a santplirtg frequency <br />schedule, as necessary, based on the scope and magnitude of the containment <br />project. It is anticipated, however, that cyanide analyses from arty containment <br />project would be for total cyanide and weak acid dissociable cyanide. <br />4. The positions of the approved ground water containment well series will be fired, <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 t/re itJ)uencc rf the approved <br />ground water containment wells befar. ir~hraling and percolating to the level r f <br />local ground water. Nothing in the proposal, as presented, considers and <br />evaluates the possibility ofsucl: an event or proposes any appropriate interception <br />andlor containment measures. <br />BMR should develop and include, as part of this technical revision, an evnhration <br />of this possibility and a description of what, if any, measures tvotrld be nec•essnry <br />and taken to deal with such a situation. <br />RESPONSE: JCHA's submittal in connection with TR-09 describes Battle Mountain's proposed <br />response to a surface flow, which would be in accordance with Sectnon 9. I of the <br />-z- <br />
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