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Letter to Nick Michael 3 June 24, 2013 <br />AM -01 Application Adequacy Review File No. M- 1990 -057 <br />demonstrating the capacity of the ditches and impoundment structures to contain operation <br />solutions and the volume of water generated by a 100 year 24 -hour rainfall event. <br />Since the Leadville Mill has been classified as a Designated Mining Operation (DMO), <br />stormwater runoff will not be allowed to report to the TSF. Stormwater must be routed <br />around the mill facility or otherwise controlled through the use of BMP's. <br />13. Please provide the tank capacities and operating solution volumes for the mill operation as <br />required by 6.3.3(2)(a). The Division must confirm that the secondary and tertiary <br />containment systems are adequate to contain 120% of the volume of the total solution in the <br />mill facility. <br />14. The Applicant has stated a portable generator will be available on site for emergency <br />conditions. Please describe how the generator will be utilized in an emergency situation. Will <br />the generator have to be manually turned on, or will it be setup to automatically turn on when <br />electrical service is interrupted? Also, demonstrate that the portable generator has sufficient <br />wattage to run the pumps and to circulate fluids through the various circuits of the mill. <br />15. As part of the approval of Technical Revision No. 3, the Applicant stated that the tails would <br />be maintained in an alkaline state and would enter the TSF with a pH of 8.0 to 9.0. The <br />current milling plan does not contain a discussion of the target pH for the tails which report <br />to the TSF. Please include a discussion of how the pH of the tails will be managed prior to <br />discharge into the TSF and specify how and at what point the pH will be measured. The <br />Division will require the tailings in the TSF to have a pH between 6.5 and 9 and the Operator <br />will be required to demonstrate that the tailings are with the required pH range prior to final <br />reclamation of the TSF. <br />16. Please describe the activities that will be conducted in the laboratory. <br />6.3.4 Exhibit D — Reclamation Plan <br />17. The proposed reclamation seed mix only includes grass species. The Division believes the <br />addition of tree, shrub and forb species to the reclamation seed mix could enhance the site's <br />use as wildlife habitat. Please respond. <br />18. The Applicant is proposing to place 18 inches of suitable material over the TSF prior to <br />seeding. Is the material to be placed over the TSF currently on the site? If so, where is the <br />material being stored and what is the source of the material? If the material will be imported, <br />then the Applicant will need to comply with the requirements of Rule 3.1.5(9) regarding the <br />importation of inert fill material. <br />19. The final cap placed over the TSF must be designed to have positive drainage. Please provide <br />a cross section drawing showing that the cap will have a crown and will provide positive <br />drainage across the TSF. <br />