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Mr. Mushinski <br /> Page 3 <br /> July 20, 2016 <br /> 12. The WRPs were not previously designated as Environmental Protection Facilities (EPF) <br /> because the geotechnical and geochemical characteristics indicated the WRPs are capped and <br /> stable and have a low potential to generate acid. The Division has determined the addition of <br /> alluvial fill to the existing WRP's will require the WRPs to be designated as Environmental <br /> Protection Facilities as defined in Hard Rock Rule 1.l(15). Therefore, the activities related to <br /> reaffecting the WRPs shall be subject to the applicable requirements of Rule 6.4.21 and Rule <br /> 7. <br /> 13. In the inspection conducted on July 28, 2016, the Division observed a small seep on top of <br /> the northern WRP. The seep was originating from the steep gulch which terminates on top of <br /> the WRP. The seep has the potential to saturate and degrade the stability of the WRP. The <br /> Operator has indicated there may be enough capacity for the excavated alluvial fill on the <br /> south WRP and the north WRP may not be reaffected. The seep must be routed around the <br /> north WRP regardless of whether additional material is added. Please describe how the <br /> Operator intends to keep the seep from coming into contact with the north WRP. As required <br /> by Rule 6.4.21(10),provide design specifications certified by a licensed professional <br /> engineer for any diversion structures which will convey, transport or divert surface water <br /> around or away from acid mine drainage or toxic or acid-forming materials. <br /> 14. Pursuant to Rule 6.4.21(6)(b),please submit a plan or narrative that describes how the <br /> excavated alluvial fill will be handled to ensure that the affected lands will be reclaimed and <br /> returned to the post-mining land use. <br /> 15. Please provide the Division with an updated Reclamation Plan Map which depicts the final <br /> configuration of the WRPs and which shows only the facilities which will remain upon <br /> release of the permit. The Reclamation Plan Map shall conform to the mapping criteria in <br /> Rule 6.2.1 and Rule 6.4.6. <br /> 16. Table 4-1: Cost Estimate of Alluvial Fill on WRPs, contains costs for the collection and <br /> analysis of soil and water samples. Please specify the analyses which will be performed and <br /> indicate when the results will be provided to the Division. If this information is already <br /> contained in the permit file, then please specify where it may be found. <br /> 17. Table E-1 from the 1983 Permit Amendment contains the revegetation seed mixture. The <br /> seed mixture contains grass species, as well as forbs, shrubs and trees. Presumably this seed <br /> mix is not specific to the WRPs as the planting of trees and shrubs on the WRP would be <br /> inappropriate. Please provide an updated seed mix to be used on the WRPs or clarify that the <br /> seed mix in Table E-1 would not include forbs, shrubs and trees in terms of revegetating the <br /> WRPs. <br /> 18. Appendix D addresses terracing of the WRPs. Cotter's response to Comment No. 4 is <br /> contained within Section 7.2 of Appendix E-4. The recommendations within Section 7.2 state <br />