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<br />Exhibit C <br />Phase I <br />Since submitting this conversion application, MDI has provided analysis which demonstrates that the <br />material in the heap leach pad contains toxic levels of cyanide. Please revise the Phase I section of <br />Exhibit C to describe hovv MDI will handle and detoxify this material for final disposal. <br />Based on these analyses, the Division could not approve this conversion to a non - DMO status while <br />the heap pad material remains on-site and toxic. However, a conditional approval might be rendered, <br />requiring detoxification and/or removal of the cyanide laden material by a specified date, before the <br />non-DMO status would take effect. This scenario is entirely dependent upon MDI demonstrating that <br />all other aspects of the operation (tailings storage/disposal, waste rock disposal, ore storage/disposal, <br />processing chemicals and processing solution strengths, storage and handling processes, etc.) do not <br />indicate that the Neglected Mine has any of the characteristics described in the definition of a <br />Designated Mining Operation. <br />Please provide a detailed schematic diagram of the milling facilities with volumes and proposed <br />maximum rates of processing through the system, concentrations of the contents of each container <br />in the process, where in the process that each chemical is added an at what concentration, and the <br />mode of transport from e~ich phase to the next. The location of the chemical storage area should also <br />be indicated with a description of how the chemicals will be kept dry. <br />3. Please confirm whether or not the proposed production rate will allow processing of the existing ore, <br />on site and above ground, within 180 days. If the ore stockpile cannot be processed and thereby <br />removed from the site within 180 days, please provide analysis documentation that proves this <br />material is not potentially acid and/or toxic producing. Be aware that if the stockpiled ore proves to <br />be potentially toxic or a~~id-forming, and is not or will not be processed within 180 days, the <br />Neglected site will be designated as a DMO. <br />4. Please indicate how the mill processing facilities pad will deal with water accumulations from <br />precipitation events that may become contaminated by spillage of milling process materials and <br />solutions within the containment pad. Also address how the operation will be winterized to prevent <br />spilling of solutions from freezing and breaking of pipes and tanks. <br />5. Please be aware that Division policy requires that any liner installation or repair be observed by <br />Division personnel, and must be conducted such that the installation can be certified. <br />6. Please characterize, as best as possible, the tailings resulting from the milling operation before and <br />after the solidification process in terms of being a toxic or acid-forming material. <br />Please describe, in detail, the tailings solidification process. The Division is concerned about how the <br />process will be conducted without jeopardizing the integrity of the tailings pond liner. Please provide <br />a schematic drawing of this process if it will aid in describing how it will occur. <br />8. Please provide detailed information regarding the proposed disposal of the solidified tailings. Details <br />should include; location within the workings designated for disposal, how the tails will be kept dry, <br />and where and how the water table has been defined. <br />The Division is concerned that the solidified tailings will be subjected to repeated wetting and drying <br />cycles when stored for disposal in a "dry" slope underground. The repeated wetting and drying <br />process could eventually break down the solidified tailings block, leaving rubble with a higher surface <br />area available for oxidization and higher potential to produce toxic ar acid mine drainage. MDI may <br />wish to consider disposal of the tailings blocks in an area that is submerged, below the water table, <br />