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Letter to Nick Michael 7 June 24, 2013 <br />AM -01 Application Adequacy Review File No. M- 1990 -057 <br />43. Please specify how much buffering material (hydrated lime) would be required to neutralize <br />all of the fluids in the mill circuits. The Division will require to Operator to have an adequate <br />amount of buffering material present at the mill at all times so that the mill circuits can be <br />totally drained and buffered in the event of permit revocation and bond forfeiture. <br />44. The Applicant has stated the current capacity of the TSF will allow the mill to operate up to <br />one year. It has been the direct experience of the Division that sites that go into bond <br />forfeiture are frequently subject to disorderly termination by Operators. The Division must <br />assume that under a `worst case scenario' the ore bunkers, coarse ore bin and fine ore bin will <br />be at full capacity. Therefore, the Operator will be required to halt milling activities when the <br />TSF reaches 80% capacity to allow for running all remaining ore through the mill and to <br />provide the 120% capacity to for all mill fluids in the event of complete failure. Please <br />respond. <br />45. The Applicant has stated that ore samples obtained from the Cross Mine are considered to be <br />representative of ore to be processed at the Leadville Mill. The Division disagrees with this <br />statement. If the Leadville Mill will operate as a custom mill, then the mill could potentially <br />receive ore that is substantially different than Cross Ore. Please provide the Division with a <br />plan for complying with Rule 6.4.21(14) which requires geochemical analysis on ore. <br />46. The Applicant has stated a tailings sampling plan has been developed. Please provide the <br />Division with a copy of this plan. <br />47. The Applicant has stated that soils less than 6 inches in depth will not be salvaged. If the <br />existing topsoil is of insufficient quantity or of poor quality for sustaining vegetation, then <br />the Operator shall remove, segregate and stockpile other materials which are best able to <br />support vegetation. Please either commit to salvaging all available topsoil or provide a plan <br />for salvaging other suitable materials. <br />48. The Applicant has stated that all chemicals will be used entirely in the milling process and <br />will be stabilized in the tailings. The Applicant must demonstrate through a chemical balance <br />that net neutralizing, metal adsorption or metal ion exchange potential can be achieved over <br />the long -term. <br />Rule 8 — Emergency Response Plans for Designated Mining Operations <br />49. As required by Rule 8.3.2(c), the Emergency Response Plan must include a list of designated <br />chemicals and maximum quantities to be stored or used on site at any one time. Please revise <br />the Emergency Response Plan accordingly. <br />50. As required by Rule 8.3.2(d), the Emergency Response Plan must include a location map of <br />materials, supplies and equipment stored on the property and readily available for containing <br />and cleaning up excursions or release of designated chemicals. Please revise the Emergency <br />Response Plan accordingly. <br />