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April 15, 2013 Division receives Operator's response to initial adequacy review <br />April 22, 2013 Division sends second adequacy review letter to Operator, noting additional <br />deficiencies in the application <br />July 23, 2013 Division receives Operator's response to second adequacy review <br />August 19, 2013 Division determines that the AM -1 application is adequate <br />OBJECTION <br />The Division received a timely objection letter on December 6, 2012, during the public comment period, <br />from INFORM. <br />Issues Raised by the Objector: <br />The issues presented by INFORM are summarized below in bold italics. The Division's responses are <br />also summarized, along with citations to the applicable sections of the Act and/or Rules. The Division <br />has listed the issues it believes to be within the jurisdiction of the Board first, followed by those it <br />believes are outside the jurisdiction of the Board. <br />A. ISSUES WITHIN THE JURISDICTION OF THE BOARD <br />1. "The inactive status of this mine is of concerti and the most appropriate action the Division <br />can take is to terminate the permit, Most recently, the Division has imposed a deadline of Dec. <br />15, 2012, on Cotter to place the mine into Temporary Cessation." <br />Division Response <br />This issue was addressed at an April 17, 2013 Board hearing, at which time the Board accepted <br />the Operator's Notice of Temporary Cessation, over the objection from INFORM, with an <br />effective date of December 15, 2013. <br />2. "Cotter's assertion that the ore will have no acid - leaching effects because of the area's limited <br />precipitation is unrealistic. Geochemical analysis of the waste rock from SR -11 indicates that <br />aluminum, arsenic, uranium, selenium and radium are all present and the rock has potential <br />to cause acid or toxic leaching. SPLP tests should not only be conducted on the waste rock, <br />but also on the ore, and not just once but on regular intervals. Ore should be removed within <br />30 days of being brought to the surface, rather than 30 days of the end of mailing, as Cotter <br />proposes The ore pad should be constructed with a clay litter, not simply a clay pad" <br />Division Response <br />SPLP tests were not conducted on the ore. The Operator has committed to submitting a <br />geochemical evaluation of the ore to the Division for review and approval prior to stockpiling any <br />ore on the surface. <br />Waste rock SPLP test results do indicate that aluminum, arsenic and selenium are present and <br />only selenium and arsenic are present at levels that exceed regulatory standards. However, the <br />EPP explains that the potential development of acid mine drainage is low due to the geochemical <br />composition of the rock forming minerals. Salt wash sandstones are commonly calcareous which <br />typically generate alkaline/basic conditions. If water percolates through the waste rock and ore <br />stockpiles, alkaline rather than acidic water would be produced, which greatly minimizes the <br />potential for acid leaching of the constituents of concern. <br />Page 2 of 4 <br />