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Cotter Corporation (N.S.L.) ( "Cotter ") submits this response to the November 8, 2013 <br />letter from Travis Marshall, Division of Reclamation, Mining and Safety ( 'DRMS"), to <br />Glen Williams, Cotter regarding the JD -9 Mine Amendment Third Adequacy Review. <br />The DRMS' comments are in italics and Cotter's responses are in bold. <br />Exhibit D <br />1. On page D -7 under item b., it is stated "During reclamation of the pad, the compacted <br />clay will also be removed and placed inside the mine. " Please specify the location inside <br />the mine the clay will be placed. Also, will any mine water come in contact at the <br />proposed final placement of the clay? <br />The August 2. 2013 response states that waste rock will be placed in a Portal <br />above the above the portal spring. Will the proposed placement of the waste rock <br />have any potential to degrade the portal spring water guaabt ? <br />The proposed placement of the waste rock inside the portal area will have no <br />potential to degrade the portal spring water quality as the waste rock placed inside <br />the portal will be significantly above the area where the portal spring shows up in <br />the portal. <br />Exhibit U <br />2. Addressing Rule 6.4.21(12), on page U -22, the EPP states that the JD -9 Mine will not <br />have any adverse effect on any surface waters; thus it is not necessary at this time to <br />implement a monitoring plan. Rule 6 4.21(12) applies to both surface and ground water. <br />Since groundwater has been encountered during mining, a minimum of three monitoring <br />wells shall be installed an up gradient well, a down gradient well and a point of <br />compliance well. The location of the point of compliance must be approved by the <br />Division prior to installation. Also, subject to Division approval, a sampling and analysis <br />plan shall be implemented in accordance with Rule 6 4.21(12) and Rule 3.1.7, regardless <br />of the results of the chemical analysis. Please commit to the installation of the mentioned <br />wells and please submit a sampling and analysis plan for review. <br />The response submitted on August 2. 2013 did not include "Attachment #3 ". <br />Please provide the maps and the water sampling and analysis plan. <br />Included with this response are Attachment # 3 from the Response to General <br />Stormwater Comments dated August 1, 2013, and the proposed sampling and <br />analysis plan for the JD -9 Mine. <br />NOv 2 g 2p13 <br />OWSION OF REC ETY <br />MINING MO SAF <br />