2007-02-06_REVISION - M1983141 ‎(3)‎

• Permit No: M1983141
• IBM Index Class Name: Revision
• Doc Date: 2/6/2007
• Doc Name: Adequacy Review Comments
• From: DRMS
• To: Mount Royale Ventures, LLC
• Type & Sequence: TR5
• Media Type: D
• Archive: No

INTEROFFICE MEMORANDUM
TO: TOM SCHREINER
FROM: DAVID BIRD -SENIOR GEOCHEMIST
SUBJECT: CASH MINE, M-1983-141
DATE: 2/6/2007
CC: CARL MOUNT
At your request, following are my comments on the reports submitted by Adrian Brown Consulting
entitled "Cash Mine Non-Designated Mining Operation Certification", dated December 10, 2006, and
"Cash Mine Comprehensive Monitoring Plan" dated November 6, 2006, on behalf of Mount Royale
Ventures for DRMS permit application M-1983-141.
1) The Dec. 10 report states that "Mine inflow occurs at approximately 2 gpm, based on testing
during mine development" Later in the same report, the statement is made ".....and after closure
the non-point source seepage from the mines to the environment is from 0 to 1 gpm....." There is
a contradiction, albeit of small magnitude, in these two passages. If 2 gpm is the current mine
inflow, and 0 to 1 gpm is the predicted dischazge, the discrepancy may need to be addressed,
depending on the site water balance and the potential impacts. What is the nature of the "noa-
point source seepage from the mines to the environment", and how was it quantifiedi' Will the
non-point source seepage include mine workings (ie., will there be discharge from the adit), or is it
anticipated that seepage will originate from fractures/faults in the surrounding country rock?
2) The Dec. 10 report states that "...during operation no water can flow from the mines to the
environment (as they are dewatered to allow working)....." What is the anticipated pumping rate
for dewatering, what is the antiapated water quality of the discharge, and what is the plan for
disposal/release of the dewatering discharge?
3) Either during operation of afrer closure, will there be times during the year (e.g, late summer
through late fall) that the mine discharge comprises the entirety of the flow in the receiving stream,
and what are the anticipated water quality impacts under these conditions?
4) The proposed list of analytes appears adequate for ground-water and surface-water monitoring.
5) The acid-base accounting tests done to date may be a sufficiently representative sampling and
characterization program. The biggest remaining question involves quantification and proportions
of the quality of discharges.
6) My primary concern is: To what extent will the products of sulfide-oxidation/acid
generation/metals dissolution affect the overall mine dischazge doting operations and after
closure? Is this component really quantifiable, or is that a question that can only be answered after