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In -situ Treatment of the Mine Pool <br />Alexco Resource US Corp (Alexco) has provided Cotter with a technical basis and conceptual <br />plan to implement in -situ treatment of mine pool water to reduce concentrations of uranium and <br />other metals through in -situ formation of sulfide minerals similar to those that likely existed in <br />the Schwartzwalder ore body prior to mining. The proposed treatment, involving controlled <br />introduction of molasses and alcohols, will also form non - pyritic iron sulfide (FeS) within and <br />throughout the mine pool workings to encapsulate the precipitated minerals and form a film on <br />wall rocks and other solid materials. This will inhibit the potential for further leaching of <br />uranium and other metals. This process is expected to greatly accelerate a consistent trend over <br />the past 5 years of steadily declining uranium concentrations in the mine pool. <br />The Alexco in -situ treatment process is not expected to reduce Ra -226 concentrations. However, <br />the immobility of radium in oxidizing environments is well documented (Ames, et al. 1983; <br />Banks, et al. 1995; Langmuir & Riese, 1985; Szabo and Zapecza, 1991) and is also evident in <br />water quality data from the site. Even if radium were transported from the reducing environment <br />of the mine pool into oxidizing environments such as zones of mixing with oxygenated <br />groundwater from the shallow alluvium, it would readily precipitate or adsorb onto natural solid <br />materials. This theoretical expectation is supported by site data indicating very low Ra -226 <br />leaching or migration potential due to oxygenated groundwater in contact with mine waste rock <br />in the alluvial fill. It is also supported by the fact that groundwater sampled from a historic <br />exploratory core hole discovered in 2010 (permanently sealed January 2011) had uranium <br />concentrations approaching those of the mine pool, yet Ra -226 concentrations were essentially <br />absent. Both theoretical considerations and site - specific data indicate that any potential seepage <br />of mine pool water that could reach oxidizing conditions in ground water regimes closer to the <br />near - surface environment would become subject to geochemical processes that readily attenuate <br />radium and prevent further migration of this constituent. There is no scientific justification for <br />an additional in -situ treatment process to reduce Ra -226 concentrations in the mine pool. <br />In -situ treatment of the mine pool would involve similar limitations to that of mine <br />dewatering /active treatment of mine water with respect to Criterion 1. This includes slow <br />groundwater travel times that could significantly delay any potential uranium reductions that <br />might be achieved in Ralston Creek once uranium levels in the mine pool have been significantly <br />reduced. However, the amount of time required to implement this measure would be <br />considerably less than that of mine dewatering /active treatment (estimated to be on the order of 4 <br />months to arrange permitting and install treatment delivery and maintenance infrastructure). <br />This would minimize the amount of time necessary to realize any beneficial effects in terms of <br />improvements in Ralston Creek water quality. <br />Other aspects of in -situ treatment have advantages with respect to each of the other remedial <br />selection criteria. First, the sustainability (Criterion 2) of in -situ treatment would be significantly <br />more favorable than that of mine dewatering /active treatment. Start up and operational costs <br />would be much lower, yet method effectiveness (Criterion 1) would likely be similar. Alexco <br />estimates that a 90% reduction in uranium concentrations in the mine pool could be achieved <br />within a matter of months following initiation of in -situ treatment. Once maximum reductions in <br />uranium concentrations in the mine pool are achieved, periodic administration of additional <br />treatment media may be required, but Alexco believes that due to very slow groundwater <br />7 <br />