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.~ <br /> <br />David Shelton <br />April 20, 1983 <br />Page Two <br /> <br />are dependent on accurate and realistic characterization of <br />the rock material. The comments for which Cotter requ=_sts a <br />deferral in response for these reasons are: D.7. and .~.8.; <br />E.6., E.B., and E.10; F.1. and F.2.; G.2.; and H.1. <br />Cotter also proposes to defer response to th~a comments <br />by the Radiation Control Division, Colorado Department of Health <br />to the extent that they also involve characterizations of <br />waste rock. Several other comments from this source pertain <br />solely to the Radioactive Materials License, and will tie <br />discussed directly with Mr. Hazle. <br />The additional investigations which Cotter proposes <br />to conduct will involve Cotter personnel, McDermid Eng._neering <br />Associates, Inc., Geo-Hydro Consulting, Inc., and an addi- <br />tional consultant, Dr. Robert Berlin of Columbia University. <br />The estimated time to complete and report is 12 weeks. Accord- <br />ingly, Cotter requests a postponement of hearing on Cotter <br />matters until the month following that period. The deferred <br />responses to comments will be provided at least two weeks <br />prior to hearing. <br />The work to be performed is: characterization of <br />leachate, if any, from waste dumps using leach test data <br />compared to calculated values based on weighted average grade <br />of mine waste and sorter reject; evaluation of N.R.C. and <br />O.S.M. leaching and transport models to determine their <br />relevance to the Schwartzwalder Mine site; and if applicable <br />selection of a model and calculation of the expected transport <br />into the creek of radiochemical and trace metal constituents <br />in surface and ground waters in response to precipitation or <br />severe erosion of waste material (this work will evaluate <br />the waste dumps in the context of final reclaimed configura- <br />tions). Based on the results of this impact analysis <br />the design of the reclaimed waste dump configuration will be <br />completed. <br />Cotter commits that upon completion of the further <br />studies and upon resolution of all matters raised in the <br />comment and response exchange, a complete .final revision to <br />the amendment application, reflecting these matters will be <br />filed. <br />