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Mr. Michael July 1, 2013 <br />AM -01 Application Adequacy Review 2 File No. M -1990 -057 <br />Certain parameters are best measured in the field due to changes that start to occur to the <br />water sample immediately after removal from the natural environment. Parameters that must <br />be measured in the field include pH and temperature. <br />The Applicant has stated that samples will be collected quarterly and reported to the Division <br />on the permit anniversary date. The Division will require the analytical results to be reported <br />on a quarterly basis; any exceedance of the established baseline conditions must be reported <br />to the Division in writing within 48 hours of such exceedance. <br />For ground water sampling, the Applicant will be required to sample all parameters listed on <br />Table 1 though 4 in Regulation 41 -Basic Standards for groundwater. Total coliform, <br />asbestos, chlorophenal, color corrosivity, foaming agents, odor, phenol, gross alpha particle <br />activity, and beta/photon emitters may be omitted from the sampling suite. Cyanide analysis <br />must be included if cyanide is being used, will be used, or has ever been used historically at <br />the site for ore processing. The Division observed drums of Cyanobrick in the mill during the <br />inspection conducted on June 18, 2009; therefore, cyanide must be included in the sampling <br />suite. The Water Quality Control Commission Regulations are stated in terms of free <br />cyanide; however, the Division prefers that Operators analyze for WAD cyanide. <br />For surface water sampling, the Applicant will be required to sample all parameters listed on <br />Tables I through III in Regulation 31 -Basic Standards and Methodologies for Surface Water. <br />D.O., suspended solids, temperature, E. Coli, total residual chlorine, sulfide and asbestos may <br />be omitted from the sampling suite. The Applicant may provide a total chromium analysis <br />rather than separate analyses of the chromium species Cr(III) and Cr(VI). <br />After a representative number of sampling events (five quarters for a DMO), and only with <br />Division approval, operators may propose to eliminate certain analytes that repeatedly <br />register undetectable concentrations in the analyses. <br />2. The Applicant has stated they will use the analytical detection limits for surface and ground <br />water samples which have been specified by the Division. The analytical detection limits <br />must be below the regulatory limits otherwise the Division will reject the data. The Division <br />recommends using method 200.8 (ICP -MS), which so far has been found to have adequate <br />detection limits for all regulated parameters. Please respond. <br />3. The Applicant has indicated there are 9 domestic wells near the mill that are located outside <br />of the unnamed tributary which drains the mill site. Figure 13 -1 shows there are two <br />domestic wells immediately down gradient of the mill site. Please revise Exhibit U to include <br />the addition of these two domestic wells. <br />In addition, the applicant has stated that there are 11 wells (9 domestic and 2 industrial) near <br />the mill. Please specify the approximate distance to these wells. Are they within 600 feet of <br />the mill site? <br />4. Currently there is only one groundwater monitoring well at the mill. The well (MW -1) is <br />approximately 20 feet deep and is completed in unconsolidated glacial outwash. The <br />