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Robert Fulton Reclamation Project 2 1 March 2011 <br />Adequacy Review File No. M-2011-007 <br />4) Rule 6.4.21 Exhibit U - Designated Mining Operation Environmental Protection Plan: <br />Rule 6.4.21(14) requires "appropriate geochemical evaluations of any material that will be exposed by <br />mining." The waste rock removal activities proposed in this application will disturb material that has <br />been undisturbed for a prolonged period and may have developed a hardened crust that is more resistant <br />to weathering than newly exposed material. The newly exposed material will potentially be more prone <br />to weathering and leaching. The suite of analytes in the SPLP test results provided are not as <br />comprehensive as the Division typically requires for sites with potential to generate acid rock drainage. <br />However, under the section entitled Waste Stream Characterization, the application states that Division <br />staff was consulted on the parameters of the SPLP test. Please provide any available documentation or <br />other verification of this consultation and that the list of analytes was approved in advance by the <br />Division. Additionally, if waste rock is disturbed but not removed within a reasonable time, the <br />Division will require an additional SPLP test of the newly exposed waste rock and perhaps stabilization <br />depending on the test results. Any new SPLP testing must include the following analytes: Aluminum, <br />arsenic, barium, cadmium, copper, chromium, iron, lead, manganese, mercury, molybdenum, nickel, <br />selenium, silver, sulfate, zinc, plus pH of the leachate. Bear in mind that the sample leachate volume <br />will need to be of adequate size to accommodate analyses of both cations and anions. The applicant must <br />also provide photo documentation of the location on the waste rock dump where the SPLP sample is <br />collected. <br />5) Rule 1.6.2.1(b) General Application Procedures <br />The Division received only one comment from the public or agencies, and a copy of that is enclosed. <br />Please copy the Division on any further correspondence to and from the agencies related to these <br />comments. The public comment period for this application closed on 28 February 2011, therefore no <br />additional public comments that pertain to this application will be considered by the Division per <br />Hardrock Rule 1.7.1(2)(b). <br />Be advised that the decision date for consideration of this application is 9 March 2011, and the adequacy <br />issues described above must be addressed by that date or the application may be denied. An extension <br />can be granted by the Division upon written request by the Applicant. Feel free to call me at 303-866- <br />3567 x8108 with questions. <br />Sincerely, <br />r, <br />David Bird <br />Division of Reclamation, Mining, and Safety