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Whetstone' <br />Associates <br />Technical Memorandum <br />of Rule 64.20(7)(e). Operator must describe any release response procedures, redundancies, and <br />"backup" measures necessary, appropriate, and economically reasonable, to control, prevent and <br />mitigate releases of the toxic forming materials from the containment facility (i.e., the alluvium) <br />outside the permit area. <br />The alluvium and fill were included in Section 7 of the EPP submitted to DRMS in August 2009. <br />Section 7, the Facilities Evaluation, lists the Environmental Protection Facilities on site. Additional <br />text has been added to the revised EPP describing the hydraulic control and mitigation strategies <br />under consideration for groundwater in the alluvium and fill. Engineering studies will be conducted <br />to determine the optimum strategy (or combination of strategies) and the mitigation measures will be <br />implemented after review and approval by DRMS. <br />8) Operator must continue to monitor the water quality of all existing monitoring wells at the same <br />locations, frequency, and with the same analytes, as has been done historically. Any modification to <br />the ground water monitoring plan must be approved in advance by DBMS. <br />Cotter agrees to monitor groundwater quality in all existing monitoring wells at the same locations <br />and frequency as has been done historically. The water monitoring plan has been updated to reflect <br />the sampling that takes place on site. This updated plan was sent to DRMS by e-mail on April 13 for <br />review. Changes between the old and new monitoring plans included: <br />* Adding MW12 to the monitoring program (well was drilled 11/2008). <br />* Removing MW4 from the monitoring program (well was removed during reclamation in <br />approximately 2005). <br />* Adding MW8 and MW10 for quarterly water level monitoring. <br />* Removing MW11 from water quality monitoring because the well was improperly <br />completed and is affected by bentonite well sealing materials. <br />* Updating the analytical suite to reflect what is currently being analyzed by the lab. <br />9) Operator must continue to monitor surface water quality at the same locations, frequency, and <br />with the same analytes, as has been done historically. Any modification to the surface water <br />monitoring plan must be approved in advance by DRMS. <br />Cotter agrees to monitor surface water quality at the same locations and frequency as has been done <br />historically. The water monitoring plan has been updated to reflect the sampling that takes place on <br />site. This updated plan was sent to DRMS by e-mail on April 14 for review. Changes between the <br />old and new monitoring plans included: <br />Adding SW-FBRG and SW-ARH to the monitoring plan (these stations have been <br />monitored since 1998 or longer). <br />* Updating the analytical suite to reflect what is currently being analyzed by the lab. <br />10) Pg 9-3: The statement is presented that the alluvial ground water is not subject to drinking <br />water standards because the water is not a drinking water source. DRMS contends that the alluvial <br />4109C.100416