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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />RESPONSE TO DAVID BIRD MEMORANDUM <br />1) Exhibit C. pg. C -l: The Applicant states: "There are no creeks or oil and gas wells <br />located either on or within 200 feet of the current or proposed affected areas. " This <br />statement may mislead the reader into believing that the requirements of Rule 6.4.21 <br />(8)(a) have not been addressed when in fact they have been addressed in the appropriate <br />section of Exhibit U Conflicting passages such as this should be avoided. <br />Cotter response: Exhibit C has been modified to state that "An inventory of creeks, <br />oil wells and gas wells was presented in the EPP (Exhibit U). The EPP concluded <br />that there are no creeks or oil and gas wells located either on or within 200 feet of <br />the current or proposed affected areas." <br />2) Exhibit D and Exhibit U: The Applicant states that mine waste material will be gobbed in <br />the mined out stopes and in lifts on ground surface. The Applicant is advised that any <br />mine development waste rock that will be disposed of in the underground workings must <br />be subjected to the same geochemical characterization as waste rock proposed for <br />disposal above ground. <br />Cotter response: The waste rock proposed for gobbing underground will not be <br />differentiated from waste rock disposed in the surface facilities. Therefore, the <br />geochemical characterization of waste rock provided in the EPP is applicable to <br />waste rock that may be placed underground. <br />Future geochemical characterization programs must be developed in consultation with <br />the Division. Failure to do so may result in the testing parameters not meeting Division <br />requirements and the possibility of having to repeat portions of the tests. <br />Cotter response: Future geochemical characterization programs at the JD -8 Mine <br />will be developed in consultation with DRMS. <br />3) Exhibit E, pg. E -I: "The material immediately below the proposed ore storage pad will be <br />removed and dumped in the shaft prior to plugging the shaft. " The applicant should <br />describe in detail the physical and geologic nature of this material. <br />Cotter response: This question refers to the upper mine area which has been <br />removed from the application. <br />4) Section 4, pg. 7. Facilities Evaluation. Diesel is not a designated chemical and unless <br />other chemicals are planned for storage in that facility, its storage area does not need to <br />be an Environmental Protection Facility. <br />Cotter response: It is acknowledged that diesel fuel is not a designated chemical. <br />The diesel fuel storage area will not be listed as an Environmental Protection <br />Page 20 <br />