2023-10-30_PERMIT FILE - M2023015 (2)

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/\A Mine'.,V�-,t d. A commitment to analyze the salvaged material for TAL metals and provide the results within one year of permit issuance to ensure replacement of this material on the surface does not have a negative impact to off-site areas. Applicant is committed to analyze the salvaged materials on at least a 5 point composited sample for TAL metals and will provide the results to DRMS within one year of permit issuance. e. A discussion of possible solutions in the event that salvaged growth media is of insufficient quantity or quality with a commitment to submit a technical revision to address the issue prior to implementation of any solution. Applicant anticipates that,if salvaged growth media is insufficient,a subsequent technical revision will be submitted to further refine the revegetation plans.There are resources available to the Applicant from on-site locations similar to that found by DRMS in 2014,including borrow pit options for recovery of fines located on-property controlled or leased by the Applicant.Also,trucks hauling away sorted product from the Site are coming back empty,and could haul in amendment materials such as compost,or import topsoil from off-site sources,at manageable incremental costs. 8. The Applicant has committed to sampling the mineralized crusher fines which will be generated from the crushing operations and will then develop an appropriate handling/disposal plan to be submitted as a revision to the permit. The Applicant has committed to a 10,000 CY maximum amount of Crusher Fines to be stockpiled on-site before obtaining approval of the handling/disposal plan revision. The Division's reclamation cost estimate will need to account for the off-site disposal of these stockpiled mineralized fines until the handling and disposal revision is approved. In accordance with Rule 6.3.4(2), please provide a thorough cost estimate for the off-site disposal of 10,000 CY of mineralized fines. MineWater has reduced the volume of accumulated Crusher Fines that can be accumulated on-site at any time to a maximum of 2,000 CY. This is reflected in the updated Exhibit U document. Applicant has conferred with our existing trucking contractor, Heartland Aggregate Mining, who has provided a quote for$0.25/ton-mile for hauling material. Penrose Landfill has provided a quote of$25/ton for disposal and is located approximately 90 miles from the London Mine. Therefore,the estimate for off-site disposal of these mineralized Crusher Fines is$72/CY. We also found that Detroit City Mine has a lump sum cost for off-site disposal of PAG waste at a price of$40/CY including trucking,so we are confident that if we are required to haul to off- site disposal locations,Applicant will be able to locate cost-effective options. EXHIBIT E—Map(Rule 6.3.5) 9. The Exhibit E Maps will need to be revised and resubmitted for review based on the following issues: