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Wally Erickson <br />Staff Notes for Adequacy 5, CN -01 <br />May Day Idaho Mine Complex, M- 1981 -185 <br />"Amendment ". The Division will not accept "Technical Review ". The absence of such <br />commitment, specifically stated within the individual work plan, is grounds for denial of <br />the conceptual plan. <br />The Division will accept individual work plans as individual Technical Revisions. If <br />Wildcat desires to submit multiple work plans together, the multiple work plans shall be <br />submitted for review through the Amendment process. <br />6. The "engineered plans" for the Environmental Protection Facilities (EPF), required under <br />Rule 6.4.21(10), contain numerous deficiencies and are grossly inadequate. As one <br />example, the application indicates the mill will be retro- fitted with a 2 -3 foot stem wall <br />to provide secondary containment. The application does not demonstrate how a stem <br />wall would be constructed in the confined space; the application does not demonstrate <br />the proposed plan is feasible. Additionally, there is a 4' concrete man -hole to be <br />constructed through the floor of the mill facility, accessing a buried 18" drain line. The <br />engineered containment plan for the mill building does not address how containment <br />will be provided with a man -hole located within the facility. According to the proposed <br />design, the drain line will be located under the existing mill facility. The application does <br />not provide any construction details for this EPF (drain line) or how it will be installed <br />without compromising the containment of the facility provided by the concrete floor <br />(and stem walls). Some of the designs for the secondary containment of the Zircon units <br />appear to be undersized and have less than adequate capacity, certainly less capacity <br />than claimed on the design sheets. <br />7. The application states there will be no new EPFs constructed, which is false. There will <br />be numerous new EPFs constructed, including the Zircon storage units with secondary <br />containment, the dewatering facility with secondary containment where the filter press <br />will be located, the containment tanks with secondary containment for the recycled <br />process fluids, the tailings and recycle fluids lines with secondary containment, the 18 " <br />drain line located under the mill facility, etc. <br />There are more outstanding adequacy issues but given the time constraint, there is insufficient <br />time to continue the list. The issues not appearing on this list are not necessarily less <br />substantial than the issues listed above. <br />4 <br />