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Geochemistry and Water Quality Review Adequacy Response <br />Wildcat May Day; DRMS File No. M-1981-185 Conversion Application CN-1 <br />Response #3 <br />Noted. <br />Adequacy Issue #4 <br />Adequate. <br />Response #4 <br />Noted. <br />Adequacy Issue #5 <br />A. The use of a ground water quality point of compliance (POC) is acceptable as a proposed <br />location for the characterization of ambient ground water quality. However, the proposal <br />to use the groundwater production well located on the May Day No. 1 bench as a POC <br />may not be acceptable. Under Hard Rock Rule 3.1.7(6)(a), the Division has the authority <br />to require more than one POC. For this site, I recommend at least two POCs, one of <br />which should be directly down-gradient of the tailings deposition location. In addition, <br />under Hard Rock Rule 3.1.7(6)(b), the Division may require a POC at the hydrologically <br />down-gradient limit of the area in which contamination has been identified, or at the <br />facility permit boundary. However, at this time insufficient hydrologic data exist to <br />accurately determine the hydrologically down-gradient limit, so the optimal location for <br />POCs based upon the hydrologic gradient remains unknown. The determination of the <br />remaining POC(s) will depend on data gathered during the baseline hydrologic <br />characterization which is yet to be conducted. The Division cannot sign off on a POC <br />location without appropriate data such as depths to ground water, directions of ground <br />water flow, hydraulic gradient, and other aquifer parameters as deemed necessary, such <br />as hydraulic conductivity. <br />B. It is important to note that the baseline characterization provides protection for the <br />Operator, and therefore inadequate characterization of baseline conditions can expose the <br />Operator to enforcement actions that might have been avoided with adequate <br />characterization. If a future violation of a water quality standard cannot be attributed <br />unequivocally to a pre-operational condition, then the Operator is liable for damages and <br />mitigation of impacts. <br />C. For all boreholes drilled in the permit area, the Applicant is strongly advised to record <br />detailed geologic logs of each borehole so as to provide the information required under <br />Hard Rock Rule 6.4.21(8)(c), i.e., descriptions of "all geologic media down to and <br />including the upper most aquifer under proposed sites of material storage, stockpiles, <br />waste piles, disposal sites, solution containment facilities and other sites within the <br />existing or proposed affected area where such subsurface materials and any associated <br />6/6/11 <br />2