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Memo to W. Erickson 2 21 April 2010 <br />Geochemistry Review File No. M-1981-185 <br />4) Section 6.3.3(1)(i). The descriptions of samples for the FLT and whole rock analyses are inadequate. <br />DBMS needs to know precisely what rock was sampled and where, supplemented with photographs <br />of the sampled material and location(s) on the ground from where they were sampled. <br />5) Section 6.3.3(1)(i). The sum of the whole rock analysis (Table C-2) for the "Type 1 - May Day" <br />sample accounts for about 15 grams, or about 1.5 % of the total mass of the sample. Is the balance of <br />the mass available in the whole rock data? As a QA measure, DRMS would also like to see acid-base <br />accounting (ABA) performed on these rock samples. Please ensure that the spatial and volumetric <br />representation of the sampling is adequate. Also please provide more details on what the sample <br />represents (location of sample, date and method of sample, etc.) <br />6) Section. 6.3.3(1)(i). Table 3 in the Christensen report indicates that several different types of sulfide <br />minerals are present, even though the Applicant submitted test results indicating sulfur was not <br />detected. In the event that sulfidic material is encountered during the mining operation, DRMS <br />would like the Applicant to submit at least one sample of the sulfidic material for testing, including <br />ABA, whole rock analysis, and accelerated weathering (e.g., SPLP), to provide an assessment of the <br />extent to which the sulfidic material may leach to the environment. The DRMS geochemist or other <br />technical staff should be present during this sampling event. <br />7) Section 6.3.3(1)(i). Tables C-3 and C-4. Please provide more details on what the samples represent <br />and where they were collected. <br />8) Section 6.3.3(1)(i). Table C-5. Please ensure that the analyte list is complete and consistent with the <br />recommendations of comment (1) above. <br />9) Section 6.3.3(1)(i). Table C-7. More information is needed on the origin of the sample labeled <br />"Mine adits". Please indicate whether the sample is discharge from the mine adit, standing water in <br />the mine, seepage from mine walls, or something else. <br />10) Section 6.3.3(1)(i), page 6. Please clarify the statement: "Groundwater monitoring wells will not be <br />completed or used for monitoring if water.is,-ri encountered 10 feet below the surface level of the <br />La Plata River." <br />11) Section 6.3.3(1)(i). Please elaborate on the "adit drainage discharge point." Is this current discharge? <br />Is it expected to continue during and after mining? What is the current flow rate? If sampling has <br />been performed, please indicate which of the attached analytical reports is for.the discharge. <br />12) Section 6.3.3(1)(k). Regarding the statement "Sampling and analysis will cease when eight samples <br />document results suggest groundwater or surface water quality will not be adversely impacted by the <br />mining and milling process." The possibility exists that rock extracted during progressively later <br />phases of mining will be geochemically different than rock mined earlier. Therefore, the Operator <br />should continue the sampling program during all phases of mining to monitor for ground water and <br />surface water impacts. <br />13) Section 6.3.3(1)(1). Regarding the statement "Sample testing will be conducted to confirm <br />preliminary findings that adverse impacts to water quality will not occur." Please elaborate on the <br />types and frequency of testing.