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Cotter Corporation (N.S.L.)'s Response to December 14, 2010 Adequacy Review, <br />Comment 11(I) <br />May 10, 2011 <br />Page 7, Item 11(I) <br />The EPP contains no provision for mine pool management other than to ignore it. It appears to <br />be the Operator's intention to use the underground workings as a geologic containment facility <br />for the mine pool water. The mine pool water is contaminated with elevated concentrations of <br />uranium, radium and other constituents as a result of disturbance of toxic material in the <br />underground mine. The Division therefore considers the flooded mine workings to be an <br />impoundment under Hardrock Rule 6.4.21(1)(c), and subject to the regulations thereto. The <br />Board and Division also consider the mine pool to be a threat to human health, property, and the <br />environment due to the risk of offsite excursions. Therefore, in addition to the Board ordered <br />actions described above in adequacy items 1.A and 1.B., Cotter must also proceed with the <br />activities described in adequacy items 3, 4, and S.B. <br />Cotter disagrees that it is "ignor[ing]" the mine pool. Please see the responses to 1(A), 1(B), 3, <br />4, and 5(B). Cotter disagrees that the flooded mine workings are an impoundment under Hard <br />Rock/Metal Mining Rule 6.4.21(1)(c). Please see the Response to Item 1(B). <br />If Cotter were to immediately begin discharge of mine pool water into the creek, many <br />constituents would require treatment prior to discharge. Cotter is proposing to treat the mine <br />pool in situ. In situ treatment will precipitate and stabilize most of the constituents referred to <br />above and will result in reduced mobility. Once stabilized, these materials will remain in a solid <br />phase, in a location where they will remain isolated from environmental release and subsequent <br />potential exposure to humans. <br />