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Sixth Adequacy Letter, Amended CN -01 <br />May Day Idaho Mine Complex, M- 1981 -185 <br />a. The Division had determined some of the proposed mining activities pose minimal <br />potential to affect surface or ground water quality. Such activities may commence <br />after the issuance of CN -01 and prior to the Division's approval of adequate <br />hydrologic information for surface and ground water. These activities are limited to <br />the following: <br />• Stabilization and reconstruction of illegal access road from County Road 124 <br />to bridge; <br />• Grading of pre- existing access roads; <br />• Installation of storm water management structures; <br />• Excavation of the collapsed portal at May Day 1 level and establishment of a <br />stable highwall and mine bench at the May Day 1 level; <br />• Removal of soil, rock and mining related debris from the drainage channel of <br />Little Deadwood Gulch at the Chief Portal and May Day 2 level; and <br />• Corrective measures as necessary to comply with enforcement actions issued <br />by other agencies, with written approval from the Division. <br />b. The Division had determined some of the proposed mining activities pose significant <br />potential to affect surface or ground water quality. Such activities may not <br />commence until the Division receives and approves hydrologic information adequate <br />to fully characterize baseline conditions for surface and ground water, and a <br />hydrologic monitoring plan sufficient to verify compliance with water quality <br />regulations. These activities, which cannot commence until hydrologic baseline <br />conditions have been approved by the Division through a permit modification, <br />include the following: <br />• Mill retrofit and commissioning; <br />• Ore stockpile consolidation; <br />• Construction of the augmentation pond; <br />• Mill optimization; <br />• Production at May Day 1 level; <br />• Production expansion; and <br />• Milling completion and closure. <br />The Applicant has committed to modifying Exhibit D, Mining Plan, to comply with this <br />adequacy issue. The mining and milling activities listed above in paragraph 11.b. may <br />not occur until the Division has reviewed and approved, through the Technical Revision <br />and /or Amendment process, the following: 1) sufficient surface and ground water data <br />to appropriately characterize baseline conditions; 2) a monitoring plan sufficient to <br />verify compliance with water quality regulations; and 3) Environmental Protection <br />Facility certifications for the entire mill facility and tailings disposal location(s). <br />12. In a correspondence dated September 16, 2011, WQCD confirmed an individual NPDES <br />discharge permit must be obtained for the discharge from the Idaho No. 1 Adit. WQCD <br />indicated the discharge could not comply with receiving stream standards without <br />treatment or dilution of the receiving stream. <br />8 <br />