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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 />RESPONSE: See the response to Mr. Mefford's first comment regarding the storage <br />coefficient. In addition, our analyses sftow the Santa Fe to be a very tight <br />formation, with a very thick unsaturated zone below the tailings facility, and a <br />seepage velocity of approximately 15 ft/yr in the aquifer. Given these <br />circumstances, BMR and CDMG have agreed through seepage analyses accepted <br />as part of the permit process, and reiterated in the June 24, 1992 Board meeting, <br />that fluids that leak from the tailings facility would not even reach the aquifer. <br />BMR believes that it is unnecessary to design a containment system at this time <br />for an eventuality that is unlikely to happen. Even if such an event did occur the <br />potential magnitude and extent of the event is currently unknown. As such, <br />designing a containment system now would not, in all probability, yield an <br />"effective ground water containment system". BMR is unaware of any instances <br />where a ground water remediation plan had to be designed and installed prior to <br />there being any knowledge regarding the magnitude and extlent of some <br />hypothetical contaminant and prior to there even being any knowledge of a leak <br />that needs remediation. <br />d. (partial) In the absence of additional infotmatio,r, it appea,s to its that ground <br />water releases in key areas of the tailings facility, the ce,rter a,-ea of the tailings <br />embankment and the collection pond area, may not be picked up ivr dre eristirrg <br />wells. Lacking any data on aquifer anistropy, we can assume that groundwater <br />flow is perpendicular to the equipotential lines delineated on Figure 7 of the <br />report. By constructing "reverse flow" lines upgrndierrt mul pe,pe,tdicular to the <br />equipotential lines, we can estimate where water moving by ndvective•/low may <br />have originated. Such lines drawn upgradient from the three nnnritor wells are <br />depicted on the attached sketch. 7&ese reverse flow lines suggest tlrnt monitor <br />wells M-9 and M-13 are most effective in identifying contnminntian which nmy <br />originate north of the main body of the tailings embank,ent. Similarly, well M- <br />12 is most effective in identifying contamination originating from the south end <br />of the tailings. None of the wells appear particularly well suited to identify <br />contamination which may originate from the collection pond, or center nj the <br />tailings embankment. <br />It is well understood that dispersion effects will cause a. comami,tm,t phone to <br />widen down-gradient. nth this in mind, the "reverse flow lines" rnny be thought <br />of as [he axis ojplumes which widen to !/te west. 77re degree to whit/t the phone <br />will widen as it moves, at least in the modeling, is dependent on dre vahres for <br />dispersivity utilized in !!re computer code. Alt/ro,tgh we have not been able to <br />reproduce dre transport conditiotrs depicted i,r the cortsultants r•elu,rt, they are <br />apparently deternrining drat the plumes will widen adequately dorvngrndient In lie <br />recog,rized in the monitor wells. To accomplish this, a lateral dispersiviy of 100 <br />feet, and a tra,uverse dispersivity of 30 feet were utilized in the calcrdatiorrs. <br />-7- <br />
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