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2"d Geochemistry Review 2 3 May 2011 <br />May Day Conversion CN-1 File No. M-1981-185 <br />B. It is important to note that the baseline characterization provides protection for the <br />Operator, and therefore inadequate characterization of baseline conditions can expose the <br />Operator to enforcement actions that might have been avoided with adequate <br />characterization. If a future violation of a water quality standard cannot be attributed <br />unequivocally to a pre-operational condition, then the Operator is liable for damages and <br />mitigation of impacts. <br />C. For all boreholes drilled in the permit area, the Applicant is strongly advised to record <br />detailed geologic logs of each borehole so as to provide the information required under <br />Hard Rock Rule 6.4.21(8)(c), i.e., descriptions of "all geologic media down to and <br />including the upper most aquifer under proposed sites of material storage, stockpiles, <br />waste piles, disposal sites, solution containment facilities and other sites within the <br />existing or proposed affected area where such subsurface materials and any associated <br />waters have the potential to be contaminated by designated chemicals used in the <br />extractive metallurgical process or by materials that are toxic or acid-forming, or that <br />produce acid mine drainage." This information will be of great use to the Applicant in <br />compliance with Hard Rock Rule 6.4.21(8). <br />6) Please see comment 5 above. Otherwise adequate. <br />7) The Applicant has not adequately demonstrated that all of the rocks in the mine are non- <br />hazardous or non-toxic-producing. Therefore, the Applicant shall conform to the <br />geochemical testing protocols as described elsewhere in the Division's adequacy reviews. <br />8) A. The locations at which downgradient impacts may reasonably be expected are not <br />well known, because the ground water system is not adequately characterized. The <br />Division should not approve the application until a baseline characterization plan and <br />hydrologic testing program are submitted that are adequate to meet the requirements of <br />Rules 6.4.21(8) and (9). <br />B. The maps and figures provided with the application indicate at least 11 proposed drill <br />pads. Some of these are in locations that might be suitable sites for conversion to <br />monitoring wells or piezometers. <br />9) Adequate. <br />10) Adequate. <br />11) Adequate. <br />12) Adequate. <br />13) A. The Applicant states that the source of water for the mill will be "from an area in <br />close proximity to the historical Idaho Mill and Portal." The Applicant should explain <br />this in further detail and indicate whether it will be ground water or surface water.