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Page 8 of 10 <br />Section (5)(b) - Based on the best information available at the time of submittal of the EPP, specify the expected <br />concentrations, process solution volumes and fate of designated chemicals to be used in the existing and proposed <br />extractive metallurgical processes at the mine, and/or mill site if applicable. Please also commit to notification of the <br />Division if significant changes will be made to this information, such as the inclusion of cyanide to the milling process. <br />Section (6) Designated Chemical(s) and Material(s) Handling - Please state how the overburden material handling to <br />be employed during operations will minimize the generation and impact of acid drainage as well as the volume of <br />water requiring treatment during and after mining (material segregation, liners, capping, etc). How will acid <br />drainage from the waste rock dumps be minimized, managed and collected (leachate capture system)? <br />Please justify the proposal of the "wet cap" reclamation of the remaining TSF areas, as opposed to the more standard <br />practice of reclamation of TSFs using a low permeability cap with positive drainage. It would seem that using the <br />"wet cap" reclamation would create a setting where surface runoff is actually captured on top of the TSF, rather than <br />shed, resulting in a greater volume of impacted water requiring treatment in perpetuity prior to discharge. As it is <br />generally understood that this facility will require post-mining water treatment in perpetuity to prevent adverse <br />impact to surface water, we believe that every attempt should be made to minimize the amount of impacted water <br />that will require future treatment. <br />Section (10) Surface Water Control and Containment Facilities Information - Why have the approximately 13 miles <br />of "clear water" diversion ditches that currently exist not been classified as an EPF as described in Section (10)(a)(ii)? <br />It would appear that they are critical to the proper operation of the facility as it currently exists, as well as vital to <br />minimizing the amount of impacted water requiring treatment prior to discharge. Have the specifications/processes <br />for the increase in dam height for the Mayflower and Tenmile Dams been certified by a licensed professional <br />engineer? If so, have these designs been reviewed and approved by a qualified independent third party? <br />Section 12 Water Quality Monitoring Plan -The Division understands that a comprehensive Water Quality <br />Monitoring Plan is currently being generated by the Operator and will be submitted under separate cover for <br />Division approval as specified in TR-08. This document shall be submitted and approved by the Division before <br />mining resumes at the site or within 365 days of the approval of AM06. <br />Section 14 Geochemical Data and Analysis -In response to Exhibit D sections (f)(i) and (ii), and Section 6.4.21(14) of <br />the EPP, please consolidate and present in a summary form all geochemical data available to date (ABA data, <br />humidity cell testing, SPLP, TCLP etc.) characterizing the waste rock material/overburden. <br />Section (16) Describe QA/QC program and measures to be employed during construction of EPFs - What QA/QC <br />processes are in place to ensure that the TSF dams and OSF are constructed and maintained according to <br />specifications? See also stability monitoring comment for Rule 6.5(4). <br />Section (18) Wildlife protection - 18(b) Describe measures to prevent wildlife from coming into contact with... designated <br />chemicals, toxic or acid forming materials, or areas with acid mine drainage. Have any measures been implemented to <br />exclude wildlife from areas of impacted waters of low pH and/or high metals content, treatment sludge deposition <br />areas, or areas where water treatment processes are active? If so, please describe and specify with maps as <br />appropriate, if not, please justify why this has not been done. <br />Exhibits V, W, X and Y apply only to In-Situ Leach Mining operations and are therefore not applicable to this <br />amendment. <br />Rule 6.5 - Geotechnical Stability Exhibit <br />(1) On a site-specific basis, an Applicant shall be required to provide a geotechnical evaluation of all geologic hazards <br />that have the potential to affect any proposed impoundment, slope, embankment, high-wall, or waste pile within the <br />affected area. The Applicant may also be required to provide a geotechnical evaluation of all geologic hazards, <br />within or in the vicinity of the affected lands, which may be de-stabilized or exacerbated by mining or reclamation <br />activities.