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2013-03-11_REVISION - M1977300
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2013-03-11_REVISION - M1977300
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Last modified
6/15/2021 5:44:24 PM
Creation date
3/13/2013 9:21:24 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
REVISION
Doc Date
3/11/2013
Doc Name
Response
From
Cotter
To
DRMS
Type & Sequence
AM4
Email Name
TAK
Media Type
D
Archive
No
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Mr. Tom Kaldenbach <br />March 8, 2013 <br />Page 4 <br />Other than the dissolution of metal oxides in the mine wall rock, which will be <br />addressed through pre - filtration processes in the RO treatment plant, there is no <br />expected effect of organic carbon on the RO treatment process. As noted in response <br />"d" above, the organic carbon will increase the density of the RO Slurry and hasten <br />the deposition of the beneficial carbon source at the bottom of the mine pool. <br />28. (This comment is intended to address comment 4 from DRMS's August 29 letter.) Please <br />provide a printout of results of model projections for the RO system. <br />Attachment 2 to this letter is a printout of the Toray Industries, Inc. modeled results of <br />specified RO treatment on Schwartzwalder mine water. Specifically, Item 3, on page two <br />shows constituent concentrations in the mine water (feed) and the resultant concentrations <br />post treatment in both the RO Retentate and the RO product or permeate. <br />29. (This comment is intended to address comment 5 from DRMS's August 29 letter.) Please <br />provide a contingency plan for disposing RO residuals outside the mine pool, should pilot - <br />scale testing or full -scale testing indicate returning the residuals to the mine pool is not <br />feasible. <br />Returning RO residuals to the mine pool, incorporated in backlit( slurry, under a UIC permit <br />by rule. is not only feasible but desirable. <br />Further, Cotter is not convinced a feasible off -site option exists. The RO Retentate prior to <br />barium chloride addition will be water with dissolved constituents present, including sulfates, <br />manganese, uranium, radium and molybdenum. Cotter is not aware of commercial off -site <br />disposal options for such a mixture of materials. Cotter has previously evaluated on -site <br />storage in ponds with water content reduced via evaporation. However, it is neither certain <br />that regulatory approval for such an undertaking can be achieved from the multiple agencies <br />involved nor that the placement of ponds is achievable considering site geography. <br />30. Please describe your involvement with EPA regarding the UIC permitting requirements <br />fbr the work proposed in your submittal. <br />Cotter is working closely with EPA regarding the UIC permitting framework and <br />requirements. It has provided additional information to EPA in response to an EPA request <br />for information. <br />31. Please provide a contingency plan and schedule for a scenario in which UIC permitting <br />cannot be completed in time for meeting the schedule shown in Figure 3. <br />In the event that an extension of the March 31, 2013 date in the September 18, 2012 Mined <br />Land Reclamation Board ("MLRB ") Order is needed, Cotter will pursue such an extension at <br />the March 2013 MLRB meeting. <br />32. Please commit to having the installation of the well in the south waste rock pile overseen <br />by a knowledgeable a trained hydro- geologist /geologist, and also commit to utilizing <br />experienced personnel for correctly installing the well. <br />
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