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Response to DRMS Adequacy Review (1) — Cotter JD -9 Mine Reclamation Plan Amendment <br />transport rate estimates of 0.04 ft/yr, discussed in the EPP, result in a travel time <br />from the area of the mine portal to Fawn Springs of 100,000 years. If it is <br />assumed that groundwater flow is controlled by the dip of the geologic structure, <br />then Fawn Springs is located more cross gradient than downgradient of the <br />mine. <br />Based on location and no groundwater seepage, there is no monitor plan for <br />Fawn Springs. <br />3. Any tailings or the clay liner from the ore pad that are disposed of within the mine <br />workings must be placed in an area where they will not come into contact with <br />groundwater. Please identify the location(s) where these materials will be placed within <br />the workings and how they relate to groundwater locations(s). <br />This comment is answered in the response to comment #7. <br />4. The Division believes that monitoring well(s) and lysimeters should be sampled quarterly <br />upon the commencement of mining activities. If the operator desires to reduce the <br />frequency of sampling, it can request the reduction through a Technical Revision to the <br />mining plan, at which time the Division will review the results of the quarterly sampling <br />to date, to determine if is appropriate to reduce the sampling frequency. <br />Cotter will sample the monitoring well quarterly and appreciates the option of a <br />Technical Revision to reduce sampling frequency <br />12 <br />