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GENERAL35134
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GENERAL35134
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Entry Properties
Last modified
8/24/2016 7:56:16 PM
Creation date
11/23/2007 8:11:27 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977310
IBM Index Class Name
General Documents
Doc Date
9/12/2007
Doc Name
Response
From
Cotter Corporation
To
DRMS
Permit Index Doc Type
JD06
Media Type
D
Archive
No
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The Division commented on the GeoScience October 19, 2005 reports in a January 17, <br />2006 letter to Cotter and stated, in pu-t, "The evaluation procedure, which was developed <br />nmh~ally by the operator [i.e., Cotter Corporation and the Division] is similar to the procedures <br />that the Division has accepted for other sites, including the Occidental Oil Shell Evaporation <br />Pond.)" <br />In summary, the Division's January 17, 2006 letter review: <br />1. Identified the rigorous nature of the Synthetic Precipitation Leach Procedure <br />("SPLP") used to test representative samples of ore and waste rock. The Division considered the <br />SPLP test to be conservative for several reasons: <br />(a) The rock samples present an extraordinarily high surface area to the <br />leachant, relative to what would be presented in the field; <br />(b) The twnbling provides maximum exposure to all reactive sites to the <br />leachant; and <br />(c) The tumbling process exposes even more surface area through semi- <br />autogenous grinding; <br />2. The SPLP test results were compared to the most restrictive (lowest value) water <br />quality standards established by the Water Quality Control Commission for groundwater in <br />Regulation 41; <br />3. Because compliance with numeric protection levels is measured in the <br />groundwater at established compliance point(s) downgradient, because there are not propagated <br />standards for dissolved constituents in unsaturated soils or bedrock, and because to push <br />contaminants to the water table requires the force -and thereby dilution by -rain or snowmelt <br />9 <br />
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