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Response to Preliminary County Comments Received on March 17, 2011 <br />Such conditions suggest a highly variable ground water system. The application fails to <br />demonstrate how the ground water system for the entire permit area can be characterized at a <br />single sampling location. The proposed plan does not satisfy the requirements of Rule 6.4.21(9). <br />The discharge from the collapsed Idaho No. 1 Adit should be included in the ground water <br />monitoring plan but the plan must also include monitoring wells at up-gradient locations, down- <br />gradient locations, and in the immediate area of the mill facility and underground tailings <br />disposal locations. Please submit a ground water monitoring plan showing the approximate <br />locations, depth, and method of construction for the monitoring wells sufficient to characterize <br />ground water conditions and verify compliance with ground water regulations. Please provide a <br />list of parameters and detection limits for ground water analysis for Division review and <br />approval. Please ensure the list of ground water parameters includes the full suite of parameters <br />listed on Table 1 through 4 in CDPHE Regulation 41, Basic Standards for Ground Water. If the <br />Applicant desires a variation from the full suite of parameters and detection limits listed in <br />Regulation 41, please submit such request for Division review. <br />After the five quarters of ground water data have been submitted and reviewed the Division will <br />approve baseline conditions through the permit modification required under paragraph (3)(b) of <br />the Joint Stipulation. <br />Response #37 <br />Ambient groundwater water quality data will be collected from the point of compliance <br />which is the proposed groundwater production well (May Day No. 1 bench). Wildcat <br />Mining proposes to drill a monitoring well north of the Idaho No. 1 spring and a second <br />monitoring well on May Day No. 2 bench. The wells are located to determine the depth to <br />groundwater and to obtain a sample to monitor groundwater quality characteristics. The <br />wells will be drilled 10 feet below the elevation of the La Plata River. If water is not <br />encountered, the hole will be abandoned and Wildcat Mining will seek a determination that <br />no additional groundwater monitoring is required. If water is encountered at or above the <br />elevation of equal to 10 feet below the La Plata River, a 4 to 6 inch well will be completed <br />and tested for production yields and water quality. If the groundwater quality has water <br />quality characteristics similar to surface and spring water quality samples previously <br />collected by Wildcat Mining, Wildcat Mining will seek a determination that groundwater <br />and surface water quality are from the same source. If surface and groundwater well <br />water quality are similar, Wildcat Mining will seek a determination that background water <br />quality is adequately characterized to address DRMS groundwater monitoring regulatory <br />requirements. If groundwater quality is significantly different from surface water, Wildcat <br />Mining will continue groundwater monitoring to characterize groundwater quality If <br />groundwater needs to be further characterized and while the groundwater is being <br />characterized, Wildcat Mining will conduct mining activities above the water table and will <br />focus on storing dry stacked tailings in the underground workings. When water is <br />encountered underground and available for sampling, Wildcat Mining will obtain <br />representative quarterly samples from representative underground mine seeps <br />Revised <br />4/14/2011 <br />22