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Memorandum <br />changes will occur. However, this notion is not supported by the hydrology or <br />geochemistry described in Amendment 8 and augmented in this TR. <br />Response: The commenter is correct in stating that changes in infiltration of <br />precipitation or chemistry as a result of the development of the ECME are in general <br />quantifiable. The quantification is illustrated below for the infiltration and the <br />geochemistry. <br />Influence on Infiltration <br />The amount of additional precipitation entering the diatreme through the ECME is <br />quantifiable and predictable, and measurable by monitoring the water exiting the Carlton <br />Tunnel, which integrates all the infiltration to the diatreme. The prediction of the <br />additional precipitation entering the diatreme as infiltration due to the proposed ECME <br />project is presented in TR-43 Exhibit F, Section 4.2, based on infiltration parameters <br />calibrated on the current project, as presented in Amendment No. 8. <br />This quantification indicates that there will be increased infiltration through the <br />approximately 50 acre footprint of the ECME during its operation (with an approximately <br />corresponding reduced diatremal infiltration due to the storage of the overburden from <br />the mine elsewhere) then no infiltration from the backfill for approximately 12 years due <br />to incident moisture uptake in the backfill, after which time the infiltration rate will return <br />to the pre-ECME level (due to reclamation of the surface of the ECME). This <br />quantification of the effect of the ECME on groundwater infiltration is refined from <br />Amendment No. 8, which (conservatively) did not take account of moisture uptake in the <br />stored overburden to return it to field moisture content. <br />The refinement has been adopted because there has been no observed increase in the <br />rate of water exiting the Carlton Tunnel as a result of CC&V mining on the 9,342-acre <br />diatreme to date, despite the prediction in earlier Amendments that there would be an <br />increase. The current evaluation was refined by including the effect of the moisture <br />uptake of the overburden produced by mining, which improves the accuracy of the <br />prediction of infiltration. <br />Influence on Water Quality <br />The evaluation of impact of infiltrating water from mine backfill in the Cresson Project <br />mines has been presented in Amendment No. 8, and that evaluation is applied in the <br />ECME TR-43 (Section 3.2). It states that any sulfide oxidation that may take place in the <br />backfill material will be neutralized by the Cresson Project-wide net neutralizing capacity <br />of the overburden rock. To the extent that any un-neutralized acidic water infiltrates the <br />underlying bedrock from the backfill, it will be neutralized by contact with the net <br />neutralizing rock along the flow pathways, and/or by mixing with the neutralizing water <br />in the regional groundwater system, prior to exiting the diatreme. Based on the analyses <br />presented in Amendment No. 8> the infiltrating water will also become locally saturated <br />with calcium sulfate and zinc species in transit through the rockmass. This process has <br />been observed since before the current mining by CC&V, and has limited the transport <br />of dissolved species to the regional ground water system both before and during the <br />CC&V mining period. Thus the acidity and concentration of species in the water exiting <br />Adrian Brown Consultants, Inc. Page 4 of 7 <br />130 West Fourth Avenue, Denver Colorado 80223 USA 9/27/2004 <br />Phone:303-698-9080Fax:303-698-9241 Email:abrown®abch2o.com 16:29 <br />