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To avoid any future misunderstandings, please indicate whether any areas that COAG intends to use <br />and revegetate (see 6. B. above) have been identified as being toxic, deficient in plant nutrients, <br />composed of sand, gravel, and cannot feasibly be remedied by chemical treatment, fertilization, <br />replacement of overburden or like measures have been identified. If so, please identify these areas on <br />the map and state which characteristics make these areas eligible for not revegetating. Also state which <br />tests(s) were used to determine this characterization, provide the limiting criteria proposed, and provide <br />the results of said test(s) for DBMS review." <br />Response: COAG Corporation is simply reminding the Division that if COAG Corporation makes <br />the decision to actively mine the site; the DRMS Rules do not require site reclamation for those areas <br />included in the mining application. If the decision is made to not mine the site, the entire area not <br />occupied by shaft closures, storage bins, host house, other previously existing structures, roads and <br />parking areas will be reclaimed according to NRCS specifications and this NOI's reclamation plan. <br />(The storage bins and other onsite structures to be used by COAG Corporation under the NOI belong <br />to the landowner. It is her desire to leave them in place and in good condition, post prospecting <br />activities) <br />e. "It is stated in the last part of the answer to question 6 that "Impacts to the hydrologic balance <br />will be minimal." because" No major aquifers are known to occur beneath the site." A statement from <br />the original Franklin Permit Application of 1983 is used to support this assertion. This statement from <br />the application reads as quoted " Because of construction of the Argo Tunnel many years ago, most of <br />the bedrock at and near the FCM (Franklin Consolidated Mine) has been drained." This statement has <br />never been verified to the knowledge of the DRMS but it is probably a good assumption that the <br />Franklin does drain to the Argo Tunnel. It is also noted that COAG states under the answer to question <br />7, through is consultant, that "...existing pools of water in the existing workings deeper in the Franklin <br />Mine." will be used for underground exploration activities. These two answers seem to be at odds with <br />one another. <br />Response: The statement concerning the pools of water was also taken from the DRMS Franklin <br />Mine permit file. Until COAG Corporation goes underground at the old Franklin Mine, it cannot <br />verify the statement. (More than likely, the pools referred to are simply puddles as one would normally <br />find in mine workings.) Regardless, COAG Corporation is clarifying that no underground drilling or <br />blasting is being proposed at this time. (However, it may be necessary shoot blocked ore shuts on <br />occasion) All bulk samples will be taken from exist tunnels and stope rubble. Therefore, the proposed <br />prospecting activity will not cause additional contributions of heavy metals to what already exists <br />underground. We therefore request that the Division not require a ground water monitoring plan and <br />five quarters of groundwater sampling under the NOI. If COAG determines that the resource is in fact <br />a viable ore reserve and f des a mining application, it will first contact the Division staff to gain their <br />concurrence as to the ground water monitoring plan and waste rock sampling and analyses. <br />It is known that the ground water from the areas drained by the Argo Tunnel are acidic and carry a high <br />metal load, necessitating the building of a water treatment plant at the mouth of the Argo Tunnel. The <br />DRMS has become the primary regulator of ground water quality at sites under its purview. The <br />DRMS must be protective of ground water quality and ensure that ground water is made no worse by