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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />Facility, and will instead be listed along with regular mine facilities in any future <br />versions of the EPP. <br />5) Section 5.2.2. 1, pg. 8. Waste rock and ore are not designated chemicals nor do they <br />generate designated chemicals. They are regarded under Hard Rock Rule 1.1 (1) as <br />potentially Acid and Toxic Producing Materials. However, under Rule 1.1 (1 5), the <br />definition of an Environmental Protection Facility includes structures that are designed, <br />constructed and operated for control or containment of uranium, uranium by-products or <br />other radionuclides, or toxic forming materials. <br />Cotter response: It is acknowledged that waste rock and ore are classified as <br />"potentially toxic- forming materials" rather than as "designated chemicals" as <br />stated in the EPP. Further, it is acknowledged that the facilities designed to control <br />or contain waste rock and ore are considered Environmental Protection Facilities as <br />correctly stated in the EPP. <br />6) Section 5.2.3.3. The Applicant should consult with the Division before conducting any <br />geochemical tests or any water monitoring program to obtain pre- approval of the test <br />and the analytes. Failure to do so may result in the testing parameters not meeting <br />Division requirements and the possibility of having to repeat portions of the tests. <br />Cotter response: Future geochemical characterization programs and water <br />monitoring programs for the JD -8 Mine will be developed in consultation with <br />DRMS, with particular emphasis on the analytical suite(s) and detection limits. <br />The Applicant must commit to ongoing and periodic geochemical testing of ore and waste <br />of run -of -mine rock at a rate to be approved by the Division. Based on the current mine <br />plan, the Division recommends collecting sample suites for geochemical characterization <br />of both ore and waste at a rate of approximately every 50,000 tons of waste rock <br />produced, or yearly, whichever occurs more frequently. The material must be subjected <br />to Acid -Base Accounting, Whole Rock and SPLP testing. The SPLP analyte list must <br />include every constituent in Tables 1 and 2 of the Colorado Water Quality Control <br />Commission Regulation No. 41, The Basic Standards for Ground Water, with the <br />following exceptions: Biological Parameters, Asbestos, Cyanide, Nitrate, Nitrite (the <br />combined Nitrate + Nitrite analysis is sufficient), Chlorophenol, Color, Corrosivity, <br />Foaming Agents, Odor, and Phenol. The analyte list must also include Vanadium, <br />Phosphorus and Hardness, and the physical parameters pH and Conductivity. <br />Cotter response: Geochemical characterization of newly -mined ore and waste rock <br />will be conducted at the stated frequency /rate stated. Specifically, at least one <br />sample of waste rock and one sample of ore will be analyzed for geochemical <br />characterization (whole rock, ABA, and SPLP) for every 50,000 tons of waste rock <br />produced, or yearly, whichever occurs more frequently. The existing waste and ore <br />have been characterized, and further geochemical sampling would commence when <br />mining resumes. <br />Page 21 <br />