Precious Metals Recovery LLC RCRA Permit Application Dry Hills ...

20.0 GROUNDWATER MONITORING – 40 CFR 270.14(c)
As required by 40 CFR 270.14(c) the groundwater system underlying the proposed TSF has been
characterized. Copies of the Groundwater Study Plan, Groundwater Study Report, and
Geotechnical Survey Report are included in this permit application as Appendices 20-A, 20-B,
and 20-C, respectively.
The proposed TSF incorporates a number of design features (e.g., air monitoring, an
impermeable membrane under the proposed TSF’s foundation, epoxy coatings on concrete
surfaces, spill trays, etc.) to detect and protect against releases of hazardous constituents to
groundwater.
Based on a thorough review of 40 CFR 270 and 40 CFR 264, it has been concluded that
groundwater monitoring is not mandated for the proposed TSF, because no regulated land based
unit is associated with the proposed TSF.
Nonetheless, independent of this permit application, the proposed TSF will voluntarily
implement a groundwater monitoring program designed to detect releases that could negatively
affect groundwater.
It is currently anticipated that the voluntary groundwater monitoring program will consist of upgradient
and down-gradient monitoring wells. This voluntary groundwater monitoring program
will be similar to other groundwater monitoring programs designed to analyze Profile I
constituents. After establishing baseline conditions, the frequency for subsequent sampling and
monitoring will be adjusted as necessary. An annual groundwater monitoring report will be
prepared and made available to NDEP.
Based on a thorough review of 40 CFR 270.14(b), it has been concluded that the post-closure
groundwater monitoring requirements are not applicable, because the proposed TSF is planned to
be clean closed (see Appendix 13-A).
PMR RCRA Permit Application, Dry Hills Facility Page 101
JBR Environmental Consultants, Inc. | HATCH March 2013