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Geochemistry Review 3 25 March 2011 <br />May Day Conversion CN-1 File No M-1981-185 <br />13) A. Exhibit G - Water Information; Rule 6.4.7(4), Projected Water Sources, page 3. The <br />Applicant states that the source of water for the mill will be the Idaho Adit near Idaho Portal <br />No. 1. Fig. C-4 indicates that the Idaho Adit #1 is "currently closed with rock pile." How is <br />the applicant able to determine the existence of, and quantity of water available, from the adit <br />in the closed condition? <br />B. Please explain the difference between the Idaho Adit and the Idaho Portal No. 1. <br />14) Exhibit T - Environmental Protection Plan; Rule 6.4.20(7)(a) [Rule 6.4.21(7)(a) under the Hard <br />Rock Rules effective Sept. 30, 2010], page 6. Please describe the process(es) that will be used <br />to prepare the tailings to "reduce the moisture available for leaching, and stored within a dry <br />underground workings." <br />15) Exhibit T - Environmental Protection Plan; Rule 6.4.20(8)(b) [Rule 6.4.21(8)(b) under the <br />Hard Rock Rules effective Sept. 30, 2010], page 6. The information provided is not adequate <br />to describe or address potential impacts to groundwater resources as required by Rule <br />6.4.21(8)(b). The depth to ground water is unknown except where ground water is observed in <br />the underground mine workings or where ground water emerges at the ground surface. <br />Therefore, the Office requires additional hydrologic testing and analyses to adequately <br />characterize the ground water regime. <br />As contemplated by the Joint Stipulation and clarified in the Division's preliminary adequacy <br />letter, dated 15 March 2011, the Operator may not be able to adequately characterize the <br />ground water regime until after CN-0 1 is issued. However, CN-01 must include a detailed plan <br />whereby the ground water regime may be adequately characterized. The plan may not be <br />implemented until after CN-01 is issued but such plan must be reviewed now, as part of CN-0 1. <br />16) Exhibit T - Environmental Protection Plan; Rule 6.4.20(14)(d) [Rule 6.4.21(14)(d) under the <br />Hard Rock Rules effective Sept. 30, 2010], page 14. The Applicant states that the pH of the <br />mined rock is 7.5. Please describe how the pH of the rock was measured. <br />17) Exhibit T - Environmental Protection Plan; Rule 6.4.20(14)(d) [Rule 6.4.21(14)(d) under the <br />Hard Rock Rules effective Sept. 30, 2010], page 14. The Applicant states that there is no <br />pathway to drinking water. In the opinion of the Division, a potential pathway to drinking <br />water exists in the form of ground water migration from the mine workings to the La Plata <br />River. Therefore, appropriate monitoring must be implemented as described in bullet 6.C <br />above. <br />18) Exhibit T - Environmental Protection Plan; Rule 6.4.20(14) [Rule 6.4.21(14) under the Hard <br />Rock Rules effective Sept. 30, 2010], Geochemical Data and Analysis, page 14. in addition to <br />the Acid-base accounting and SPLP analyses, the applicant is required to submit one sample of <br />tailings for a long-term humidity cell test under ASTM method D5744-07. The sample to be <br />submitted shall be selected in consultation with DRMS. The test shall commence as soon as <br />possible and continue for the life of the project or until permission is received from DRMS to