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Mr. L. Dobson <br />11 /14/03 <br />Page 4 of 7 <br />"is completed in the deep mine pool associated with the Bulldog Mine." In contrast, Homestake's <br />discussions with the WCRC indicate that the Bassett well is not completed in the deep mine pool. <br />Table 4.1 -This [able should be checked for errors. For instance, i[ is unlikely that [he Bach well <br />and the Eggert well produce yields of 1310 gpm and 920 gpm, respectively. <br />Comments on Recommendations in the PA <br />For purposes of providing comments on the Recommendations in Section 6 (pages 34-37 of the PA), <br />each of the eight bulle[ed action items is discussed below. <br />1. As discussed in General Comment 1 above, the water level in the deep mine pool is well below <br />the plug elevation and the plug has performed in accordance with its design specifications. The <br />plug is 24 feet in length and is constructed of concrete. Considerable care was taken to pressure <br />grout the formation around the plug. The plug will not fail if the pressure reaches 11 psi. Thus, the <br />first recommendation that Homestake develop a contingency plan for draining water from behind <br />the adit seal is no longer applicable. <br />2. Homestake expresses no comment on the second recommendation in the PA. <br />3. Homestake conducted extensive monitoring during the tracer test from September 1999 to <br />September 2001, The monitoring schedule for the tracer test work, as agreed to via agency permit <br />approval, is provided in Table ]attached. As reported in this table, extensive sampling was <br />conducted and the analyses were submitted in monthly reports [o the Division of Mineral and <br />Geology (DMG), Durango Field Office. Based on the third recommendation, it does not appear <br />that SAIC reviewed these monthly reports. <br />The purpose of the tracer test was to confirm that the water ponding behind the plug in [he 9360 <br />adit did not reach Windy Gulch via some "short circuit" pathway such as a major fracture. A two- <br />year study period was agreed to with the DMG. The results of the tracer test sampling and analysis <br />demonstrate that a "short circuit" pathway does not exist. Accordingly, there is no technical <br />rationale for continued [racer test monitoring at this time, as suggested in the third recommendation. <br />4. Homestake installed a new cutoff structure, bypass pipe and lined surface overflow ditch at the <br />9360 waste rock facility during October -November 2002, almost one year after the field study <br />supporting the PA was conducted. Thus, the activities suggested in the fourth recommendation <br />have been fully addressed and are no longer applicable. <br />5. Homestake installed the cutoff structure and bypass pipe to eliminate the potential for water <br />flowing down Windy Gulch to contact waste rock material. Homestake also installed a vegetative <br />soil cover over the 9360 waste rock facility. The soil cover will reduce infiltration and potential, <br />direct exposure to human and ecological receptors. Thus, the activities suggested in the fifth <br />recommendation have been fully addressed and are no longer applicable. <br />6. The Fall, 2002 reclamation activities conducted by Homestake at the 9700 waste rock facility <br />included construction of an upstream cutoff and bypass pipe to eliminate potential contact between <br />Windy Gulch flow and the waste rock. The facility also has been capped with a vegetative soil <br />cover. Thus, the activities suggested in the sixth recommendation have been fully addressed and <br />are no longer applicable. <br />6919-D Acnoc Nr Rono NE, A~auquersque, NM 891Q9 Tee: 1505) 828-1621 FAX: (SQS) 828-1626 <br />