2013-06-24_REVISION - M1990057

• Permit No: M1990057
• IBM Index Class Name: REVISION
• Doc Date: 6/24/2013
• Doc Name: AM-01 ADEQUACY REVIEW - 1
• From: DRMS
• To: OPERATOR
• Type & Sequence: AM1
• Email Name: MAC
• Email Name: TAK
• Media Type: D
• Archive: No

Letter to Nick Michael 4 June 24, 2013
AM -01 Application Adequacy Review File No. M- 1990 -057
20. The Applicant has proposed applying straw mulch at a rate of 1 ton per acre. The Division
and the NRCS recommend applying mulch at a rate of 2 tons per acre. Please respond.
21. The Applicant has proposed installing stormwater BMP's following reclamation in order to
convey water around and through the site. Please describe any ditches, swales or sediment
control facilities to be used to control stormwater.
22. The Reclamation Plan states the stored topsoil will provide less than 1 inch of topsoil over
existing disturbed areas. Please note that topsoil must be salvaged from any areas which are
not currently disturbed, but will be disturbed in the future. See additional comments under
Exhibit C, No.I l and revise the amount of topsoil to be replaced accordingly.
23. The Reclamation Plan states that 50lbs of seed will be applied to the site. This seeding rate
far exceeds what the NRCS has recommended. Also, the seeding rate specified by the NRCS
is for broadcast seeding. Therefore, the rate should be reduced by half for drill seeding.
Please commit to using the seeding rate recommended by the NRCS.
24. The Reclamation Plan calls for conducting geochemical characterization of the tailings prior
to placement of the topsoil cap. Please specify the geochemical analyses the Operator intends
to conduct.
25. As required by Rule 6.3.4(2), please provide a detailed estimate of the cost to reclaim the
site. The estimate should include the following information:
a) A list of all structures with specifications for dimensions and construction materials,
including foundation thickness.
b) A plan for sealing all monitoring wells and the associated costs.
c) Costs associated with removing stormwater BMP's.
d) Costs associated with dismantling and disposal of mill equipment. The costs should be
for disposal at an approved off -site facility.
e) Costs associated with the removal and disposal of all utility infrastructures.
f) Operating costs associated with disposal of all reagents, assuming that the maximum
volume of each chemical will be on site.
g) Cost associated with milling the maximum volume of ore to be stored at any given time.
6.3.5 Exhibit E — Map
26. Figure 6 -2 depicts a circular shaped facility on the east side of the crushing building. The
Division assumes that this is the ore storage bunker. Please label this facility on Figure 6 -2.
27. Figure 6 -2 depicts a new crusher facility and truck scale. The Division understands that these
facilities are conceptual and will be addressed under a future permit revision. Please remove
these structures from Figure 6 -2.