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AM-02 EPP Adequacy Review 2 14 December 2010 <br />Schwartzwalder Mine File No. M-1977-300 <br />(3) A plan and schedule for development and or expansion of the appropriate water treatment <br />system that will be needed to treat the expanded suite of constituents and to handle the increased <br />pumping rate, including at a minimum: <br />i. Expansion of the pumping volume capacity to provide the mandated drawdown within a <br />sufficiently short time period such that the pumping will be immediately effective in <br />establishing the hydraulic gradient back toward the mine pool. <br />ii. Installation of additional treatment circuits to remove components in the mine pool in <br />addition to uranium that have concentrations above water quality criteria. These <br />components include, but are not necessarily limited to: antimony, arsenic, iron, manganese, <br />molybdenum, radium, sulfate, and thallium. <br />iii. Expansion of water storage capacity sufficient to handle volumes of overflow or excess <br />water that may be discharged in the event of short term emergencies, plant malfunctions, or <br />other circumstances. <br />iv. A plan for disposal of the treatment sludge, including short term storage on site and long- <br />term transport and disposal off site. <br />V. A plan for installation of a sufficient number of piezometers situated at appropriate locations <br />in the vicinity of the mine pool and Ralston Creek that will allow monitoring of the cone of <br />depression and the hydraulic gradient, and hence verification of the success of the mine <br />dewatering effort. <br />vi. A plan for procurement of the required permits from other agencies, or amendment of <br />existing permits. <br />vii. If solicitation of an RFP is to be included as part of the plan, then the specifics of the <br />solicitations including review, startup, timelines, and deliverables will be subject to review <br />and approval by the Division. <br />B) The Division regards the mine dewatering and treatment as only a temporary measure to be <br />implemented while a long-term sustainable solution is devised. It is apparent from previous <br />correspondence that the operator's intention has been and will continue to be that the underground <br />workings will be used as a geologic containment facility for the mine pool water. The mine pool water <br />is contaminated with elevated concentrations of uranium, radium and other constituents as a result of <br />disturbance of toxic material in the underground mine. The Division therefore considers the flooded <br />mine workings to be an impoundment under Hardrock Rule 6.4.21(1)(c), and subject to the regulations <br />thereto. Therefore, in addition to the dewatering and treatment required under the Board Order, Cotter <br />must proceed with the following: <br />(1) Provide a detailed plan for long-term decommissioning or stabilization of the mine pool to <br />prevent off-site excursion, or alternatively, a plan for detoxification of the mine pool such that if an <br />excursion occurs it will not adversely affect human health, property, or the environment, keeping in <br />mind that stabilization of one hazardous compound, e.g., uranium, will not necessarily result in