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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />(12) Section 10, the Construction Schedule and the associated Table 24 have an error that <br />effects the entire information presented. As noted in the mine permit review, the status of <br />the production of the mine has no bearing on the EPP requirements. Site characterization <br />and stormwater control structures shall be required to be installed regardless of any <br />other activities on site upon approval of the EPP plan. Cotter must submit a construction <br />schedule that identifies when these activities will be initiated upon approval of the EPP <br />not "contingent upon resumption of active mining ". <br />DATES <br />2005 — <br />present <br />2006 <br />Jan 2007 - <br />present <br />Feb -11 <br />Sep -12 <br />Sep -12 <br />TBD <br />TBD <br />TBD <br />TBD <br />TBD <br />Cotter response: A revised Construction Schedule has been developed (see Table 1, <br />below), which omits reference to active or intermittent mining status. The schedule <br />for the construction of stormwater control structures is related to the buildout of the <br />mine. Construction can begin soon after approval of the revised Drainage Design <br />Plan for the proposed expansion of stormwater control structures to contain the 10- <br />year, 24 -hour storm under the existing conditions. The construction of post - mining <br />stormwater control structures will occur following the cessation of mining activities, <br />when the waste rock pile has been built up and configured to fmal grade. <br />Table 1. Construction Schedule <br />ACTIVITY STATUS <br />Maintenance of existing stormwater BMPs Ongoing <br />Lysimeter installation <br />Lysimeter monitoring <br />Relocation of temporary ore stockpile into underground storage <br />area <br />Retention Pond 1 and spillway construction <br />Retention Pond 2 enlargement and spillway /culvert <br />construction/installation <br />Implementation of operational stormwater BMPs <br />Sealing of mine portals <br />Decommissioning of fuel storage area <br />Implementation of post - mining stormwater BMPs (including <br />diversion ditch construction, removal of Pond 1 and Pond 2, <br />construction of Pond 3) <br />Waste rock pile final reclamation <br />Page 12 <br />Complete <br />Ongoing <br />Complete <br />Pending (contingent on DRMS <br />approval of revised Drainage <br />Design Plan) <br />Pending (contingent on DRMS <br />approval of revised Drainage <br />Design Plan) <br />Pending (timing is contingent on <br />mine buildout) <br />Pending (post mining) <br />Pending (post mining) <br />Pending (post mining) <br />Pending (post mining) <br />(13) The EPP does not address Quality Assurance and Quality Control as required under <br />Rule 6.4.21(16) and Rule 7.3.1(4). <br />Cotter response: Rule 16 says to "describe the Quality Assurance and Quality <br />Control program and measures to be employed during construction of those <br />Environmental Protection Facilities that typically warrant Quality Assurance and <br />Quality Control." The quality control for construction of stormwater BMPs will <br />