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2012-03-05_REVISION - M1977300
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2012-03-05_REVISION - M1977300
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Entry Properties
Last modified
6/15/2021 3:11:59 PM
Creation date
3/6/2012 3:01:52 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
REVISION
Doc Date
3/5/2012
Doc Name
ENVIRONMENTAL PROTECTION PLAN
From
COTTER
To
DRMS
Type & Sequence
AM2
Email Name
AJW
Media Type
D
Archive
No
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Mr. Anthony J. Waldron <br />March 1, 2012 <br />Page two <br />Minnesota portal and that it intended to submit a technical revision request if supported by the <br />assessment. On October 6, 2010, DRMS approved TR -14. <br />On December 22, 2011, Cotter submitted to DRMS its report that was contemplated by the TR -14 <br />approval. The report was entitled "Characterization, Remedial Criteria and Disposal Options for <br />Alluvial Fill Source Term Materials at the Schwartzwalder Mine Site." After a technical evaluation, <br />Cotter stated that disposal of waste rock inside the mine would not significantly change water <br />chemistry of the mine pool, nor would it increase any potential for migration of mine water that <br />could impact local ground or surface water resources. Cotter also evaluated the options of disposal in <br />an engineered waste rock pile and of off -site disposal, and concluded that placement in the <br />underground has the most advantages and fewest disadvantages versus other options. Pursuant to the <br />terms of the TR -14 approval, Cotter should have the opportunity to present a technical revision <br />request. Cotter requests that Paragraph 6 of Attachment A allow for a technical revision request and <br />for the possibility of other disposal options after further technical discussions with DRMS. <br />Cotter remains concerned about the adverse environmental impacts and other problems with mine <br />dewatering and treatment, and about the need or advisability of dewatering to 500 feet below the <br />Steve Level. It is convinced that in situ treatment would dramatically reduce concentrations of <br />uranium within the mine pool and is concerned about the delay in allowing Cotter to perform such <br />treatment. As you know, Cotter submitted written information to DRMS regarding in situ treatment <br />on March 14, 2011 and May 7, 2011, and made presentations to DRMS on March 7, 2011 and on <br />November 7, 2011. Cotter is particularly concerned about delays associated with the amendment <br />process when the Mined Land Reclamation Act allows for a more expeditious means of permitting <br />through a technical revision. Nonetheless, Cotter will pursue an amendment for in situ treatment. <br />Cotter reserves the right to respond by April 1, 2012, to DRMS' application and interpretation of the <br />term `Environmental Protection Facility" with respect to the Schwartzwalder Mine, as set forth in <br />Attachment A. Cotter does not oppose an appropriate monitoring plan for the underground <br />workings. <br />Cotter remains committed in its attempt to resolve the disagreements with DRMS and MLRB over <br />the best technical approach to address the environmental issues at the Schwartzwalder Mine. Cotter <br />believes, and the data confirms, that substantial progress has been made in reducing concentrations of <br />uranium in Ralston Creek, particularly in the second half of 2011 to date, and believes that further <br />reductions will be achieved once the Ralston Creek diversion project starts operating. We look <br />forward to trying to work out additional technical solutions with DRMS through the permit <br />amendment process, technical revisions and technical discussions. <br />Very truly yours, <br />5 <br />John S. Hamrick <br />Vice President, Mill Operations <br />2 <br />
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