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17. On Page 27, Environmental Protection Plan, Exhibit U, U (7.b), please clarify if any springs or <br />seeps were documented. <br />18. On Page 27, Environmental Protection Plan, Exhibit U, U (7.b), please note that depending on <br />the geological stratigraphy and other information submitted by Rimrock the number of up <br />gradient and down wells and their locations will be established. <br />19. On Page 29, Environmental Protection Plan, Exhibit U, U (8.b), Surface Water Containment <br />Construction Schedule, please clarify why there is no Milestone #2? Please note that the <br />Division must be contacted in writing a minimum ten (10) working days prior to initiation of any <br />structure construction. The Division, at its discretion, may wish to be present either to observe <br />pre- construction preparations, construction, or post construction of any EPP structure to ensure <br />QA /QC. <br />20. On Page 39, Environmental Protection Plan, Exhibit U, U (13.a.3) (3), please provide the basis <br />for a limit of 100 uR /hr as a final reclamation standard for waste pile rock. <br />21. Please submit information required for Rule 7.3 and 7.4 for Environmental Protection Facility <br />design, construction, certification, QA /QC, and inspections. <br />22. Please address the technical issues presented by Division Geo- chemist David Bird in the <br />attached September 13, 2011 memo. <br />23. Please address the technical issues presented by Division Engineer, Tim Cazier, in the attached <br />October 7, 2011 memo. <br />This review is a preliminary adequacy review. The Division will review operator responses, data, and <br />information for technical merit and completeness. No decision will be made until the application meets <br />the requirements of the Act and Rules. The applicant is responsible for placing this and all other review <br />documents at the County Clerk Office in Nucla for public review in a timely manner. No further public <br />comments may be accepted. <br />Please note the current decision date for this amendment is October 24, 2011. Based on the additional <br />information required more time will be required to gather, submit, and review prior to the current <br />decision date. Staff is recommending that Rimrock submit an extension request that gives them ample <br />time to address these issues and allow for Division review. An extension request must be filed with the <br />Division by no later than October 24, 2011. <br />