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<br />' January 12, 1995 <br />Bulldog Mine <br />Page 3 <br />At the initiation of mining in 1967, Homestake also settled a <br />' water right civil action. This was the "irrigation" agreement <br />discussed with the DMG during our December 21, 1994 meeting. In <br />that case, the protestants challenged Homestake's request to change <br />the point of diversion of surface water rights in the area. In the <br />' court settlement Homestake was entitled to divert surface water <br />flows from either the Rio Grande River or Willow Creek, subject to <br />some volume limitation conditions (Attachment E). This case was not <br />' related to groundwater withdrawals from the Bulldog Mine. <br />' Water Oualitv <br />As mineral development began in this area in the late 1800's <br />there is no pre-mining groundwater information for this area. There <br />' are no known existing wells in the vicinity of the Bulldog Mine. <br />In August 1974 Homestake obtained its first NPDES discharge <br />' permit for the dewatering of the Bulldog Mine. In developing a <br />water treatment plant to meet the discharge effluent limitations <br />Homestake also looked at other sources of potential water impacts <br />in the Willow Creek drainage. This investigation indicated that the <br />I Willow Creek drainage, above Windy Gulch and the Bulldog mine <br />discharge, was elevated in Zn, Mn, Cd and other metals. This <br />suggests that drainage from the Nelson Tunnel may likely have been <br />' a source of metal loading into Willow Creek long before development <br />of the Bulldog Mine. <br />' In addition, Homestake collected and analyzed pre-treatment <br />water quality from the Bulldog Mine. These data were collected in <br />1975 and are considered the earliest available ground water quality <br />data from the Bulldog area (Attachment F). These data revealed that <br />' mine dewatering from the Bulldog Mine (without treatment) <br />represented less than 4% of the total metal loading in Willow <br />Creek. <br />Discharge water from the Bulldog Mine was subsequently treated <br />until 1987 to meet NPDES permit effluent limitations. In 1987, <br />mining ceased and the pumps were removed from the mine. The water <br />treatment plant was then donated for use at the Summitville Mine <br />remediation effort. <br />' As presented in the March 2 NPDES permit inactivation request <br />the workings of the Bulldog Mine on Windy Gulch, and the workings <br />of the Nelson Tunnel and associated mines on Willow Creek, are not <br />' interconnected. The quality of water draining from the Nelson <br />Tunnel is dependant on the mineralization of the upgradient mine <br />workings. <br />1 <br /> <br />