Laserfiche WebLink
Letter to Jay Jones -2- November 29 1995 <br /> of the SWMP to satisfy the requirements of TR-08 will also be <br /> sufficient to satisfy the requirements of Rule 6.4. 19 (10) (b) . <br /> 4. Rule 6.4. 19 (7) (d) discusses monitoring activities that may be <br /> necessary to evaluate the effectiveness of Environmental Protection <br /> Facilities. Rule 6.4 . 19 (11) (b) discusses surface water quality <br /> monitoring to serve as a basis for the evaluation of reclamation <br /> performance standards success, and to insure the adequacy of <br /> Environmental Protection Facility design, maintenance and operation. <br /> Rule 6.4. 19 (12) requires that a surface water monitoring plan be <br /> proposed where necessary to demonstrate that the EPP requirements <br /> are being met. It is the Division's understanding that intensive <br /> surface water quality monitoring is required in the Tenmile Creek <br /> basin by the Climax Mine CDPS Permit. We further understand that <br /> pertinent water quality data is available for the Arkansas and Eagle <br /> River sides of the Climax Mine area from the aquatic biological <br /> monitoring program referenced in the original Reclamation Permit <br /> application and amendments. It is the Division's view that a <br /> surface water monitoring program may be necessary for the Arkansas <br /> and Eagle River basins in order to satisfy the requirements of the <br /> Rules cited above. Please provide a narrative description of the <br /> monitoring that has been conducted, and a tabulation of pertinent <br /> data, as well as a proposal for on-going monitoring. Decisions <br /> regarding the necessity and specifics of a surface water monitoring <br /> program will be made based on the data available and upon your <br /> proposal. <br /> 5. Rule 6.4. 19 (5) requires a presentation and discussion of designated <br /> chemical concentrations. In section 5.3.2 of the EPP application it <br /> is stated that solid NaCN is initially mixed and stored in a 3300 <br /> gallon tank at 5 percent NaCN in solution; cyanide solution is also <br /> stored in a 240 gallon tank above #6 float cell, presumably at the <br /> same concentration. Please provide information on the range of <br /> cyanide concentrations, in milligrams per liter, that may be <br /> expected once the 5 percent cyanide solution is fed into the <br /> flotation circuit. Also provide the molarity of phosphorous <br /> pentasulfide at the point of mixing and dissolution, and the <br /> molarity sodium hydroxide solution, and sulfuric acid as it is <br /> stored at the site. <br /> 6. As discussed above, up to 3540 gallons of 5 percent NaCN solution is <br /> stored in the mill building. In section 5. 1. 1.2 of Appendix B to <br /> the EPP application it is indicated that spills in the cyanide <br /> storage room would report to a floor drain which flows to the <br /> tailing delivery system. The Division is concerned with the <br /> potential for short term wildlife exposure to cyanide in the event <br /> 5 percent NaCN solution were to be spilled and discharged to a <br /> tailing impoundment. It is the Division's view that mechanisms must <br /> be in place to assure that the 5 percent NaCN solution is adequately <br /> diluted prior to being discharged to a tailing impoundment in the <br />