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Response to DRMS Adequacy Review (1) — Cotter JD -9 Mine Reclamation Plan Amendment <br />26 Addressing Rule 64.21(10) (a), Please provide design specifications certified by a <br />licensed professional engineer for all Environmental Protection Facilities. This includes <br />the water treatment facility, water treatment ponds and water transport infrastructure for <br />mine dewatering to the water treatment facility. <br />Consistent with the response to Comment #10, Cotter will submit an engineering <br />plan certified by a licensed professional engineer that includes the water <br />treatment facility, water treatment ponds, and the water transport <br />infrastructure from dewatering operations. <br />27. Regarding the ponds the operator must commit to using a double lined design with a <br />leachate collection/detection system. Furthermore, the division will require the <br />installation of piezometers as a secondary method of leachate detection. Please commit <br />to incorporating the requirements into the engineered design specifications. <br />Cotter agrees to all above stated requirements regarding the pond liner design <br />and engineering design specifications. <br />28. Addressing Rule 6.4.21(12), on page U -22, the EPP states that the JD -9 Mine will not <br />have any adverse effect on any surface waters; thus it is not necessary at this time to <br />implement a monitoring plan. Rule 6 4.21(12) applies to both surface and ground water. <br />Since groundwater has been encountered during mining, a minimum of three monitoring <br />wells shall be installed an up gradient well, a down gradient well and a point of <br />compliance well. The location of the point of compliance must be approved by the <br />Division prior to installation. Also, subject to Division approval, a sampling and analysis <br />plan shall be implemented in accordance with Rule 6 4.21(12) and Rule 3.1.7, regardless <br />of the results of the chemical analysis. Please commit to the installation of the mentioned <br />wells and please submit a sampling and analysis plan for review. <br />Cotter will install two additional monitoring wells to complement the existing <br />monitoring well. Cotter does request that groundwater conditions at the site be <br />considered, and that Rule 6.4.21 (1) (d), providing for consideration of economic <br />reasonableness and technical feasibility in ensuring compliance, be taken into <br />account. As noted in the EPP, groundwater transport rates for the Salt Wash <br />8 <br />