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AM-02 EPP Adequacy Review 5 14 December 2010 <br />Schwartzwalder Mine File No. M-1977-300 <br />7) Rule 6.4.21 (10) - Surface Water Control and Containment Facilities Information <br />In accordance with Rule 6.4.21 (1 0)(a)(ii), if the operator is unable to mitigate the release of <br />contaminants from the AFA in the vicinity of the mine, they should include in the TR required in <br />adequacy item LA a provision to convey, transport, or divert surface water around or away from the <br />AFA, as it contains quantities of toxic material that are adversely impacting the environment. <br />8) Rule 6.4.210 1) - Surface Water Quali y Data <br />A) Section 11(c)(ii), page 11-11. The EPP states that no surface water standard has been established <br />for molybdenum. The Operator should be advised that Water Quality Control Commission (WQCC) <br />Regulation No. 31, The Basic Standards and Methodologies for Surface Water, amended 9 August 2010 <br />and effective 1 January 2011, includes a 30-day surface water domestic water supply standard for <br />molybdenum of 210 gg/L (total recoverable). <br />B) Section I I (c)(iii), page 11-55. The EPP states "Infiltrating water which contacts these reactive <br />surfaces solubilizes the stored uranium salts and transports uranium into the groundwater system." Has <br />the operator done any geochemical analyses to identify the stored uranium salts that are present and <br />their chemical compositions? If not, what uranium salts are assumed to be present and what is the basis <br />for the assumption? <br />9) Rule 6.4.21(12) - Water Quality Monitoring Plan <br />The analytical suite for the quarterly monitoring of the mine pool should be expanded to include the <br />following parameters: Bicarbonate (as HCOA boron, chromium (dissolved or total), fluoride, lead <br />(dissolved or total), nitrate + nitrite (as N), phosphorus (total as P), gross alpha, gross beta. <br />10) Rule 6.4.21(14) - Geochemical Data and Analysis <br />Provide comment on the significance of the reported charge imbalance of -46.77% for the speciation <br />calculation for the average water quality of the upper mine workings reported in section 14(b)(iii). 1. 1. <br />Does it indicate a deficiency in the cation analysis, and if so which cation(s), or is it more an artifact of <br />the averaging? <br />11) Rule 6.4.21(15) - Construction Schedule Information <br />A) In accordance with Rule 6.4.21(15), the operator must provide a detailed construction schedule for <br />all facilities designed to contain uranium, uranium by-products or other radionuclides, toxic or acid- <br />forming materials. It appears to be the Operator's intention to use the AFA as a facility to contain <br />uranium and other contaminants and prevent them from migrating to Ralston Creek. For this reason it <br />is appropriate to include in this section a discussion of the provisions of this Rule. <br />B) Section 15(a)(iii), page 15-3. The EPP discusses a possible detailed human health risk assessment to <br />determine potential pathways for human exposure and possible alternative concentration limits. So long <br />as the AFA is in direct hydraulic communication with Ralston Creek, which is a drinking water source, <br />the Operator must take measures designed not only to reduce the concentrations of contaminants in the