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Mr. Eric Scott <br />Climax Mine - Response to DRMS Adequacy Review Comments <br />. Permit M-1977-493; Amendment AM-06 <br />March 1, 2011 <br />Page 13 of 16 <br />shall be submitted and approved by the Division before mining resumes at the site or within 365 <br />days of the approval of AM06. <br />Response: A Water Quality Monitoring Plan was submitted by CIVIC to DRMS (then DMG) in 1995 <br />as part of TR-08. As stated in Section T-6 of the EPP, CIVIC recognizes that refinement of the <br />Groundwater Monitoring Program will be addressed in a future submittal for review and approval <br />by the Division before full-scale operations resume. In addition, CIVIC acknowledges the concerns <br />over potential impacts to Eagle Park Reservoir and Clinton Reservoir that were expressed in July <br />8, 2010 letters to the Division from Eagle Park Reservoir Company, Clinton Ditch and Reservoir <br />Company, and the Eagle River Water and Sanitation District. Although no impacts are expected, <br />CIVIC will examine the hydrologic conditions in the areas of concern and will incorporate, if <br />appropriate, any additional monitoring measures necessary to provide further protection of surface <br />water into the Groundwater Monitoring Program for Division review and approval. <br />Exhibit U/Section (14) Comment: Geochemical Data and Analysis -In response to Exhibit D <br />sections (9(i) and (ii), and Section 6.4.21(14) of the EPP, please consolidate and present in a <br />summary form all geochemical data available to date (ABA data, humidity cell testing, SPLP, <br />TCLP etc.) characterizing the waste rock material/overburden. <br />• Response: Geochemical data, including acid/base accounting, pH data and metals data (both <br />SPLP and total metals), have been summarized in the attached tables, and will be included as <br />Appendix D to the revised EPP. Data were collected from overburden material, road fill material, <br />tailing material, and material from each of the TSFs. Soil samples were analyzed, as well as water <br />samples from waste rock reactors constructed on McNulty OSF. The data are summarized in <br />several tables identified as Tables T-D-1 through T-D-S, attached. <br />Exhibit U/Section (16) Comment: Describe QA/QC program and measures to be employed during <br />construction of EPFs - What QA/QC processes are in place to ensure that the TSF dams and OSF <br />are constructed and maintained according to specifications? See also stability monitoring <br />comment for Rule 6.5(4). <br />Response: The revised EPP, to be submitted at a later date, will incorporate additional QA/QC <br />information as appropriate, however the following response is provided in the interim. Specific <br />QA/QC requirements will vary depending on the facility being constructed and the construction <br />methods employed. Project specific QA/QC requirements will be included with future design <br />submittals for EPFs, to be submitted in accordance with Rule 7.3. In general, the QA/QC program <br />will consist of construction observation, inspection of materials for use in construction, survey <br />control and field measurements, and appropriate field testing during construction to ensure that <br />work is conducted and completed in accordance with the project-specific design and technical <br />specifications. Certification of construction will be provided to the Division, including appropriate <br />QA/QC documentation. <br />As described in Section T-5.5.3 of the EPP, monitoring of the TSFs includes water level monitoring <br />through the use of piezometers equipped with data loggers and visual observation of seepage.