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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />hydrologic information provided in the JD -8 EPP. In contrast with the direction of <br />surface water flow, any precipitation that might infiltrate to groundwater on the <br />escarpment would flow toward the southwest, along the dip of the bedding planes of <br />the subsurface geologic units. <br />The lysimeter data provided in the EPP indicates there are no saturated units below <br />the JD -8 Mine waste rock pile. The lysimeter is dry and there is no evidence of any <br />contamination from the JD -8 Mine reaching the Pinon Ridge Mill Site or any other <br />facility. <br />Given these inconsistencies and questions, more detail is necessary for Cotter to provide <br />the required detailed information on groundwater pathways that may contribute to the <br />groundwater contamination evident at the mill site, located just below to the northwest <br />from JD -8. This additional information is consistent with the Rules, which require 5 <br />quarters of data showing water quality and quantity among other detailed information. <br />See e.g. Rule 6.4.21(8), (9), (11), (12) and (14). <br />Cotter response: The JD -8 is a dry mine. The EPP contains two years of lysimeter <br />data showing that the subsurface below the waste rock pile is also dry. Installing <br />additional dry wells would not provide any useful data on water quality at the mine. <br />Cultural Resource Assessments Are Not Complete <br />Given the reported high number of historic and prehistoric cultural, archaeological, and <br />paleontological resources in the area, the Division should coordinate with the Colorado <br />SHPO to ensure that Cotter has appropriately inventoried, identified, and mitigasted <br />impacts to, all historic resources at the site. <br />Cotter response: Cotter contracted with an archaeological contractor to evaluate <br />the concerns SHPO has indicated that they have regarding the permit areas. <br />Abandoned Mine Features in the Area Should Be Considered for Reclamation <br />As part of any EPP, the Division should explore with Cotter the potential for reclamation <br />work to be accomplished on these abandoned mines to improve and mitigate the wildlife, <br />water quality, and other impacts in the area. <br />Cotter response: Cotter has done reclamation of some abandoned mine features on <br />other properties in this area in the past. Reclamation of abandoned mines, whether <br />pre -MLRA or not, on other private or public property should not be a requirement <br />for approval of the JD -8 Mine Permit Amendment. <br />Page A -5 <br />