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Environmental Protection Plan, Schwartzwalder Mine 15 -9 <br />(g) Mine Pool Stabilization and Detoxification <br />The plan for stabilization and detoxification of the mine pool will be developed as part of ongoing <br />mitigation activities and investigation. The mitigation program must follow a logical path forward, to <br />prevent uranium migration into the creek, followed by further investigation and source removal in the <br />alluvium and fill, identification and sealing of any potential conduits between the mine pool and Ralston <br />Creek, and evaluation of strategies for mine pool treatment and stabilization. <br />In -situ treatment of mine pool water will be conducted to accelerate the current trend of decreasing levels <br />of uranium in the mine pool, reduce concentrations of other metals, and coat interior wall rocks and mine <br />rubble with a layer of iron sulfide that will physically and chemically inhibit further geochemical leaching. <br />Alexco Resource US Corp (Alexco) has provided Cotter with a technical basis and conceptual plan to <br />implement in -situ treatment of mine pool water to reduce concentrations of uranium and other metals <br />through in situ formation of sulfide minerals. The proposed treatment will also form non - pyritic iron sulfide <br />(FeS) within and throughout the mine pool workings to encapsulate the precipitated mineral forms of <br />uranium, inhibiting the potential for re- dissolution or release of the uranium back into the mine pool. In situ <br />mine pool treatment would be performed under Technical Revision 17 (TR 17) to Mining Permit M -1977- <br />300. <br />(h) Monitoring Well Installation <br />Four bedrock monitoring wells are proposed for installation in 2011: an upgradient (west- southwest) pair <br />of replacement monitoring wells for existing wells MW10 and MW11, and a downgradient (east) pair of <br />new bedrock wells. <br />(1) Replacement Upgradient Bedrock Monitoring Wells <br />The upgradient pair are intended to fulfill the requirements of the December 14, 2010 EPP Adequacy <br />Review (DRMS, 2010) which requires that bedrock monitoring wells MW10 and MW11 be replaced with <br />new upgradient monitoring wells to determine baseline bedrock ground water quality and thus serve as a <br />basis for the evaluation of reclamation performance standards. <br />MW10 and MW11 were originally installed for the purpose of determining water levels above the mine and <br />understanding the groundwater flow system in the bedrock. The wells are still suitable for this purpose, <br />although their use as monitoring wells is compromised due to bentonite intrusion into the screened zones. <br />Two new monitoring wells will be drilled in 2011 to determine bedrock water quality upgradient of the <br />deposit in an area that has not been mined. The proposed location is in the SE1/4 of the SW1/4 of Section 25. <br />The replacement bedrock wells will be located in the same quarter - quarter section and within 500 feet of <br />the existing wells MW10 and MW11. The replacement wells will be accessed via a previously disturbed <br />road, although additional permitting and earthwork will be required to construct the drill pad. The <br />proposed locations will be field verified and staked, prior to a contractor orientation and pre -bid meeting <br />for qualified drilling contractors. An application will be submitted to DRMS describing the acreage of <br />proposed disturbance, proposed well completion depths and materials, reclamation plan for the disturbed <br />area, monitoring methods, and provisions for future access to the monitoring wells. The paired wells will <br />be located within 100 feet of each other, and will be completed at different depths (as were MW10 and <br />MW11) to determine vertical hydraulic gradients. Sampling will be performed using approved passive <br />sampling methods (see ITRC, 2007) to avoid the potential for bentonite intrusion that occurred at MW10 <br />and MW11. Because the monitoring methods may depend on the depth to water encountered in the <br />4109C.110510 Whetstone Associates <br />