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Scott, Eric <br />From: Scott, Eric <br />Sent: Wednesday, March 07, 2012 1:34 PM <br />To: Lazuk, Raymond <br />Subject: TR -20 adequacy comments <br />Ray- <br />Here is a summary of DRMS comments that will need to be addressed for TR -20 (Tenmile Stability Analysis and <br />Operations /Maintenance Plan). I know this is a very abbreviated format compared to the usual adequacy letters, so if <br />you have any questions regarding these comments please don't hesitate to contact me for clarification. <br />- Who is the "Engineer of Record" and what is their review frequency for the monitoring data collected in the <br />weekly /event reports? <br />- Will there be an in -depth inspection (similar to the "annual inspection" or better) conducted to document pre- <br />operational baseline conditions before deposition begins? <br />In Table 3 -6 (and a few others) is the "post earthquake" FOS evaluation for the OBE or MCE? <br />Sec. 4.4.4 Are there any environmental concerns associated with using a petroleum based dust suppressor <br />(Coherex) in this application? <br />Sec 5.2.1 Will there be surveyed markers placed for visual assessment of the required 6ft of freeboard and /or <br />minimum 500ft beach width to make sure upper operating level is not exceeded? <br />Sec 5.3.2 Are there plans to install a flume to monitor the flow rate of discharge from South Portal of the <br />Tenmile tunnel as suggested? <br />Sec 6.1/6.2 The trigger levels for the pizeometer monitoring program need to be specified. <br />- Sec 6.3 What is the expected response time for the URS on -call support if there are anomalies observed? <br />What are the plans to implement other recommendations, such as additional monitoring wells, <br />monitoring /sampling tailings characteristics, etc. that are presented in these documents (specifically Section 5 of <br />the Stability Analysis)? These processes need to be in place ASAP so that startup conditions can be monitored, <br />and any required adjustments to the process as outlined can be made in a timely fashion. <br />Sec 6.4 Monthly monitoring inspections should not be entirely suspended in winter months, however, DRMS <br />realizes that certain allowances may need to be made for access /safety reasons or snow cover. Conditions <br />requiring exceptions to the normal inspection protocol should be well documented. <br />Thanks. <br />Eric Scott <br />Environmental Protection Specialist <br />Division of Reclamation, Mining and Safety <br />1313 Sherman St Rm 215 <br />Denver CO 80203 <br />Ph 303 - 866 -3567 x8140 <br />Fax 303 - 832 -8106 <br />1 <br />