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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 remedialion plan, it is <br />noted that interceptor wells may need to be installed downgradient of the bermed <br />area within the drainage "to create a hydraulic barrier and, thus, control all <br />contaminated ground water, which would then Ue 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 />S. ltutallation of wells necessary to control the hydraulic gradient downgradient of <br />the tailings facility will not accomplish this control in a tirnely way unless all <br />accessory equipment necessary, i. e., pumps, tubing, etc., are a.va¢lable. <br />BMR should commit to provide, as part of its eventual ground water containment <br />plan, such details of welt design mtd accessory equipment as rvi11 be installed, <br />maintained on site, etc. , in order to provide assurance that the welds intended for <br />use in controlling in the hydraulic gradient, dedicated or odrerwise, cmt be <br />quickly acrd effectively put to or converted to srrclt trse. <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 wafer seepage <br />velocities in this area are approximately 0.04 feet per day (14.6 feet 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 plUrne evidences <br />itself, it is not known how many wells, or at what exact locatlions, will be <br />necessary. However, BT•9R will, upon evidence of ground water contamination, <br />immediately move to install the necessary wells and equipment and begin the <br />ground water containment project. <br />6. Contamination of unsaturated soils by surface flow from the tailings facility Wray <br />occur, but "appropriate actions" to be taken by BMR with dre ntater4al, following <br />analysis, are not specked. <br />BMR should commit to receiving Division approval of the disposition of such <br />samples before such final action is taken. <br />RESPONSE: The Emergency Response Plan addressed how BMR would respond 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 acknowledges it may <br />also need other agency approvals prior to disposition of contaminated soil. <br />-3- <br />