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2011-04-18_REVISION - M1981185
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2011-04-18_REVISION - M1981185
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Last modified
6/15/2021 5:58:11 PM
Creation date
4/19/2011 8:02:52 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1981185
IBM Index Class Name
REVISION
Doc Date
4/18/2011
Doc Name
Response to preliminary and second adequacy issues (CN-01) Part 1 attachments A-E
From
R2Incorporated
To
DRMS
Type & Sequence
CN1
Email Name
WHE
DB2
PSH
ACS
Media Type
D
Archive
No
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Response to Preliminary County Comments Received on March 17, 2011 <br />C. The Division will require at least two ground water monitoring wells between the lower <br />most mine portals of the May Day and Idaho areas and the La Plata River. Since the <br />Applicant is planning on drilling additional exploratory boreholes, the Applicant may <br />convert, depending on location and in consultation with the Division, some of the <br />boreholes to 2-inch monitoring wells and 1-inch piezometers. The parameters for ground <br />water sampling should conform to Tables 1, 2, 3, and 4 of WQCC Regulation 41. <br />Response #6 <br />The point of compliance for surface water will be SW-2 located down gradient of the mine <br />site and located on La Plata River. <br />The point of compliance for groundwater will be at the mine pool, the groundwater <br />production well or at the base of the proposed dry stack tailings disposal site.. DRMS has <br />not accepted the Idaho Spring water quality as being representative of groundwater <br />therefore alternative points as described in the previous sentence are being offered as <br />groundwater points of compliance. Groundwater monitoring, wells may be completed if <br />groundwater is encountered during future exploration activities. Wildcat Mining has <br />adopted the groundwater sampling requirements referenced by DRMS and set forth in <br />Regulation 41. <br />Secondary Preliminary Adequacy Issue #7 <br />Exhibit E - Reclamation Plan; Rule 3.1.5(2), item 2, page 6. The reclamation plan proposes to <br />permanently dispose mill tailings and debris from the dismantled mill facility in the underground <br />workings. The application does not demonstrate such plan will be compliant with the ground <br />water quality regulations. The Division cannot approve the proposed reclamation plan until the <br />Applicant demonstrates such plan will be compliant with the ground water regulations and <br />protective of existing and reasonably potential future uses of ground water, per Rule 3.1.7. <br />Response #7 <br />Wildcat Mining will dispose of mill material in an environment that will eliminate water <br />quality impacts and concerns per rule 3.1.7.. Wildcat Mining has demonstrated the mine <br />rock is not hazardous or toxic producing and has demonstrated the chemicals to be used to <br />concentrate ore will not impact the environment. The mine has been in operation since the <br />early 1900s and surface and groundwater quality has not been affected by past mining <br />activities. Based on all presented data, Wildcat Mining submits that water quality impacts <br />will be minimized or prevented. <br />Secondary Preliminary Adequacy Issue #8 <br />Exhibit E - Reclamation Plan; Rule 3.1.7(7)(a), Ground water monitoring, page 11. The locations <br />at which down gradient impacts may reasonably be expected are not well known, because the <br />Revised <br />4/14/2011 <br />28
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