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M MW Sorter <br /> VV <br /> and setup, commencement of MSHA oversight, commissioning of ore sorting facility with initial test <br /> program for calibration, processing will then commence generating ore grade materials for off-site <br /> processing, and waste generation. Once waste is characterized geochemically (ABA, SPLP+Zn, MWMT if <br /> needed), results will be presented to the Division and if necessary amendment will immediately be <br /> implemented to prevent acid-forming conditions. <br /> Once sufficient waste rock has been removed to begin exposing native soil horizons in the South London <br /> Stockpile area,soil stockpile will be constructed and re-placement of mineralized fines at the upgradient <br /> edge of the disturbance areas will commence. Placement of fines in haul-truck wheel-compacted lifts 2 <br /> foot lifts will occur to ensure that not more than 10,000 CY of fines are accumulated at any time in the <br /> screening area.Upon achieving final planned grade for the fines, inert material will be placed on the outer <br /> slopes and top surface and covered with salvaged topsoil,amended if needed with compost and fertilizers, <br /> and revegetated. <br /> DRMS(Item#33): The Division has reviewed Exhibit U and has determined application does not address <br /> all sections of the Rules. Please submit a revised Exhibit U addressing all requirements outlined under Rule <br /> 6.4.21.At a minimum,please provide information addressing all sections of Rule 6.4.21(7), 6.4.21(8), Rule <br /> 6.4.21(11), Rule 6.4.21(12), and Rule 6.4.21(13). <br /> MW Sorter(Item#33 Response): MineWater is providing our response to each rule listed below: <br /> Rule 6.4.21(7): <br /> a) Site Specific Conditions: Monitoring of the sources to the Water Tunnel are conducted under <br /> Paragraph 39 of the Consent Order IC160803, including identifying sources of electrically <br /> conductive water flowing to the Water Tunnel, and then prioritizing remediation efforts toward <br /> the most heavily impacted water sources.The Water Tunnel is the dominant drainage feature at <br /> the London Mine and has been decreed to be the source of water rights and has been used since <br /> 1912 for hydraulic control of the drainage from the Site to South Mosquito Creek. Applicant has <br /> identified through repeated surveys of the Water Tunnel that the area beneath the South London <br /> Stockpile is the largest load of dissolved zinc to the Water Tunnel, although the South London <br /> Stockpile itself is not a major source. Removal of a large portion of the mineralized rocks located <br /> on this area,will reduce the loading to the environment,but more importantly the reclamation of <br /> the area will reduce the amount of infiltration down previously unreclaimed features such as the <br /> American Shaft and collapses adjacent to the Shaft. Drainage from this facility will either report to <br /> the Water Tunnel, or flow overland to the South Mosquito Creek monitoring location. Quarterly <br /> reporting will demonstrate the benefits of the work. <br /> b) The London Mine drainage effluent is not acidic.The pH of the discharge from the Water Tunnel <br /> is 7.8 and even when the site was abandoned by the Estate from 2010-2016 the pH never became <br /> acidic (below pH 6.5) in the untreated discharge.The facility contains all stormwater impacted by <br /> contact. Materials are not themselves acid forming or toxic as they exist today. Once fines are <br /> generated, every 5,000 CY of fines will be sampled and if any concerns exist these fines will either <br /> be taken off-site for processing,or handled through adaptive management actions in consultation <br /> with DRMS comprising compaction,alkalinity amendment(blending with existing dolomitic waste), <br /> inert covers,and/or revegetated soil cover. <br /> 131 Page <br />