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• <br />Memo to Berhaa Keffelew <br />CC~VG LVSCS ALR Response <br />page 2 <br />I am at a loss to resolve Mr. Hardaway's contemporary opinion with <br />the wording of CC&VG's Amendment Number 6 application. On page 6- <br />21 of the application, CC&VG stated; "An ALR (Action Leakage Rate) <br />constitutes a trigger for initiating interactions between the owner <br />of a containment unit and the regulatory agency." CC&VG, <br />subsequently within pages 6-22 and 6-23 of the permit application, <br />specified ALR's and corresponding proposed Response Actions to be <br />taken by CC&VG. CC&VG's statement of its ALR's and Response <br />Actions is prefaced with the statement; "Based on the approach <br />taken to determine the liner leakage rates, the response levels <br />proposed are as follows: ... Upon approval of the permit <br />amendment these ALR's and the corresponding Response Actions became <br />conditions of the permit. <br />To be absolutely precise, I later determined that the ALR proposal <br />within the original application specified a methodology but not <br />specific ALR response flow rates. CC&VG submitted "...Information <br />Updating the Estimation of Leakage Rates" by letter from John <br />Hardaway on June 13, 1995. Attached to Mr. Hardaway's cover letter <br />was a document entitled "REVIEW OF THE LOW VOLUME SOLUTION <br />COLLECTION SYSTEM ACTION LEAKAGE LIMIT RATES", prepared by Dr. Dirk <br />Van Zyl, PhD. and Terry Manziak, both of Golder Associates, <br />consultant to CC&VG. That review included a table presenting <br />specific fluid recovery pumping rates versus pregnant fluid head <br />(depth in feet) for each of the three ALR probabilistic action <br />response levels (50~ exceedence, 90~ exceedence and 98~ <br />exceedence). <br />In his June 13, 1995 cover letter attached to that submittal, Mr. <br />Hardaway stated: "This information updates section 4.8 of that <br />portion of the approved Mining and Reclamation Plan contained in <br />Volume II of the Application (as 'Appendix 1') and titled <br />'Permitting Level Design Evaluation of the Expansion of the Mining <br />and Ore Processing Facilities - Cresson Project.' That section <br />draws upon experience with solid waste land fills to project <br />anticipated leakage rates and to identify actions that an operator <br />would undertake should leakage meet numeric levels." <br />Based upon the above observations, I am operating upon the opinion <br />that CC&VG committed to a set of Response Actions tied to a <br />proposed, and later clarified, set of Action Leakage Rates. My <br />concern expressed last month related directly to my conclusion that <br />the current inflow rate being experienced by CC&VG within the LVSCS <br />of its Phase 2 valley leach pad is currently exceeding its <br />specified 98~ exceedence ALR. However, CC&VG is not completely <br />complying with its specified Action Responses for that situation. <br />The appropriate Action Response, labeled "above 10~ exceedence" in <br />