2011-08-22_GENERAL DOCUMENTS - C1980006

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Mid -Term Responses Adeq Review u y , 1. The Division has reviewed the revised maps and accepts the modifications showing the revised permit area. However, two additional comments arose from our evaluation. a. The Division needs one set of maps with original signatures per Rule 2.01.3(2). b. The Sudduth lease legal description is included in the permit and in the exhibits accompanying the bond and the permit. Please remove reference to T9N, R78W, Section 15 on pages 778 -18 and 778 -20aa of the permit application and revise Exhibit A of the Westchester Fire Insurance Company Bond and the legal description accompanying the July 10, 1986 mining permit. This issue had been discussed this spring when a replacement bond was acquired. At that time, Mr. Munson requested deferral of the issue to the resolution of the mid -term. 2. The revisions to Exhibit 58 to include the disturbance near Pond G look acceptable. As the Division is holding a $5.5 million bond, no modification of the bond is required at this time. However, Kerr should be aware that review of the bond will accompany the permit renewal slated to commence September 20, 1990. At that time, material balance issues will be revisited, and the Division asks Kerr to be prepared to provide topography maps which reflect existing and pre - mining topography at the site. The value of the bond will be recalculated to reflect the reclamation remaining at the site. 3. a. Table 5a indicates that the overburden geochemistry data found in Table 73a is reported from the bottom of the hole to the ground surface. Examination of the columns entitled 'thickness' and 'depth' suggest that the data is presented from the top of the hole darn to the bottom. Please clarify this issue and revise Table 5a if necessary. KCC claims that the high SAR value of 25. 2 in a sample collected on 10 -8 -80 from Drillhole No. 028- 80 -28C is a result of contamination by drilling fluid. No supporting analyses of the drilling fluid were included so it is impossible to say whether the samples were contaminated and to what degree they were contaminated. It is interesting to note that samples collected on 10 -31 -80 showed SAR values of 3.3, 16.9, and 9.6. The 16.9 value was obtained from the same sampling interval as the previous 25.2 value. KCC goes on to state that " .,. corresponding data collected from other drillholes (028- 80 -021C, 028- 80 -23C and 028- 80 -24C) which intersected the same geologic strata support the contamination argument." This statement is only partially true in that drillhole 028 -80 -23C is the only hole that intersects similar geologic strata. When SAR values are compared in the same geologic strata, these values are relatively high (12.9) and show the same general trends, as Drillhole No. 028- 80 -28C. The sample from 028 -80 -23C was composited over 118 feet so the compositing may mask high SAR values of any one zone. Drillhole 028 -80 -23C was drilled using no drilling fluid so samples should not have been contaminated.