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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />(2) Please see David Bird Memo, Item 4, regarding diesel fuel as not being a designated <br />chemical. While not a designated chemical, petroleum products in general do need to be <br />handled correctly. Secondary containment is essential and the monitoring of those <br />structures within the plan is acceptable. <br />(3) <br />(5) <br />Cotter response: The applicable EPP requirements will be implemented as <br />required. Cotter understands that the EPP requirements for stormwater <br />management and baseline hydrologic and radiometric characterization are not <br />contingent on active or intermittent status. <br />Cotter response: Cotter acknowledges that diesel fuel is not a designated chemical <br />and is aware of, and committed to, the proper handling and storage of diesel fuel. <br />Please see David Bird Memo, Item 5 regarding the definition of designated chemical <br />classification of waste and ore rocks. Terminology is important and the materials are <br />considered toxic forming, not designated. Please revise the AM -01 application as <br />necessary. <br />Cotter response: Future submissions will identify the waste rock and ore as <br />"potentially toxic - forming materials" and not as designated chemicals. <br />(4) Section 5.2.2.2, the EPP and Mine plan must clearly state that ore will not be left on the <br />surface for more than 180 days and that ore will be not be left on the surface in the event <br />of a mine shut down longer than 30 days. Please revise this section accordingly. <br />Cotter response: Revised Exhibit D — Mining Plan (attached) has been amended to <br />state that ore will not be left on the surface for more than 180 days and that ore will <br />not be left on the surface in the event of a mine shutdown for longer than 30 days. <br />Any revisions to the EPP will also include this statement. <br />Please revise section 5.2.2.2 to clarify the handling of rock used in underground gobbing, <br />as was requested in the mine plan review. <br />Cotter response: As stated in the response to Item # 6 of the Application Review <br />(above) and summarized in the attached revised Exhibit D — Mining Plan, waste <br />rock will be gobbed into mined out stopes. Site - specific hydrogeologic data confirms <br />that the JD -8 Mine is unsaturated, as summarized in the technical memorandum, <br />entitled "Hydrogeologic Data Compilation for the JD -8 Mine," dated April 13, 2012 <br />(provided as Attachment 6 (see Revised Supporting Documentation for Exhibit U)). <br />The water table occurs below the contact of the ore zone, and the existing workings <br />have remained dry. The gobbed material will not contact any groundwater below <br />the water table. <br />(6) The discussion of constituents of concern in Section 5.3.1.7 and 8 does not address the <br />current on site radiation levels both man -made and natural. Please submit a radiometric <br />survey of the mine site to establish a site specific baseline of current conditions. The <br />Page 9 <br />