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Response to Preliminary County Comments Received on March 17, 2011 <br />Secondary Prelimingy Adequacy Issue #15 <br />Exhibit T - Environmental Protection Plan; Rule 6.4.20(8)(b) [Rule 6.4.21(8)(b) under the Hard <br />Rock Rules effective Sept. 30, 2010], page 6. The information provided is not adequate to <br />describe or address potential impacts to groundwater resources as required by Rule 6.4.21(8)(b). <br />The depth to ground water is unknown except where ground water is observed in the <br />underground mine workings or where ground water emerges at the ground surface. Therefore, <br />the Office requires additional hydrologic testing and analyses to adequately characterize the <br />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 ground <br />water regime until after CN-0 1 is issued. However, CN-01 must include a detailed plan whereby <br />the ground water regime may be adequately characterized. The plan may not be implemented <br />until after CN-0 1 is issued but such plan must be reviewed now, as part of CN-0 1. <br />Response #15 <br />See the groundwater response provided in Response 5 and Attachment H <br />Secondary Preliminary Adequacy Issue #16 <br />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 />Response #16 <br />The paste pH procedure was used to measure rock pH. <br />Secondary PreliminM Adequacy Issue #17 <br />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 the 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 River. <br />Therefore, appropriate monitoring must be implemented as described in bullet 6.C above. <br />Response #17 <br />Dry stack underground tailinlls disposal methods have been adopted to eliminate potential <br />water quality concerns with the mine operation. An appropriate groundwater and surface <br />Revised <br />4/14/2011 <br />31