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:~ <br />The Operator has represented, stridently, that not only aze their proposed "Temporary <br />Modifications and Qualifiers" the equivalent of "Ambient" standards - in the Clean Water Act.sense <br />of the term -but also that these should be considered operative in assessing potential discharges from <br />the site to surface waters. Since the Operator's proposed standazds deviate significantly from what <br />the WQCD has stated to be in place surface water standazds, it is obviously imperative that the <br />Operator have the issue clarified. <br />Therefore, we strongly recommend that application of Pad 2 material to the Hwy 67 Road <br />Relocation be curtailed unless and until the Operator adequately explains to the Division how such <br />application will cause no upsets of surface or groundwater quality standazds. We suggest also, <br />provided the Operator stands by their position that the operative standazds are the proposed interim <br />standards for surface water, that the Operator secure a written explanation from the WQCD which <br />standards apply now or in the future. <br />Finally, we urge the Operator to evaluate their existing information in light of potential geochemical <br />processes that might as to reduce the metals' (or other regulated parameters') quantities and raise <br />the pH of potential effluent. The operator might consider alternative processes such as dilution by <br />interstitial or intervening fluids, mineral precipitation, or adsorption and, for groundwater, probably <br />transit times from possible effluent points to permit compliance points. Also, as stated in past <br />correspondence from the Division to the Operator, the Operator should consider means of <br />minimizing the influx or meteoric water to ore and waste rocks, and thus minimize the outflow. <br />cc: Bruce Humphries <br />Jim Stevens <br />Jim Pendleton <br />M:\MIIJ\HI-~\JUNE.REV <br />4 <br />