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Third Adequacy Review 2 5/27/2008 <br />COAG Corporation P-2007-069 <br />Specifications of the Colorado Inactive Mine Reclamation Program, 2006" or adequately bonded <br />under the Notice of Intent prior to any prospecting activity on site. <br />6. a. If the site is proposed to be left as an industrial site, please indicate that such zoning <br />exists on the site at this time. <br />b. Please specify which areas will have vegetation established upon them on the map <br />provided and state how large the area is. <br />c. Please indicate whether COAG will follow all the recommended NRCS methods <br />specified on the areas indicated. <br />d. Under the last part of the answer to this question, it is stated "COAG is aware that no <br />planting is required on the following areas: ;a) On lands proposed for future mining. b) On any <br />affected land so long as the chemical and physical characteristics of the surface and immediately <br />underlying materials of such affected land are toxic, deficient in plant nutrients, or composed of <br />sand, gravel, and cannot feasibly be remedied by chemical treatment, fertilization, replacement of <br />overburden or like measures." To avoid any, future misunderstandings, please indicate whether <br />any areas that COAG intends to use and revegetate (see 6. b. above) have been identified as being <br />toxic, deficient in plant nutrients, composed ;of sand, gravel, and cannot feasibly be remedied by <br />chemical treatment, fertilization, replacement of overburden or like measures have been <br />identified. If so, please identify these areas on the map and state which characteristics make these <br />areas eligible for not revegetating. Also state which test(s) were used to determine this <br />characterization, provide the limiting criteria proposed, and provide the results of said test(s) for <br />DRMS review. <br />e. It is stated in the last part of the answer to question 6 that "Impacts to the hydrologic <br />balance will be minimal." because "No major aquifers are known to occur beneath the site." A <br />statement from the original Franklin Permit Application of 1983 is used to support this assertion. <br />This statement from the application reads as!quoted "Because of construction of the Argo Tunnel <br />many years ago, most of the bedrock at and near the FCM (Franklin Consolidated Mine) has been <br />drained." This statement has never been verified to the knowledge of the DRMS but it is probably <br />a good assumption that the Franklin does drain to the Argo Tunnel. It is also noted that COAG <br />states under the answer to question 7, through its consultant, that "...existing pools of water in <br />the existing workings deeper in the Franklin !Mine." will be used for underground exploration <br />activities. These two answers seem to be at odds with one another. <br />It is known that the ground water from the areas drained by the Argo Tunnel are acidic and carry <br />a high metal load, necessitating the building of a water treatment plant at the mouth of the Argo <br />Tunnel. The DRMS has become the primary 'regulator of ground water quality at sites under its <br />purview. The DRMS must be protective of ground water quality and ensure that ground water is <br />made no worse by prospecting or mining activities than when such activities started. Without <br />baseline water quality parameters, a prospector or operator may be held to the table value