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Response to Preliminary County Comments Received on March 17, 2011
<br />water monitoring and point of compliance programs will be established to demonstrate
<br />compliance with applicable water quality standards.
<br />Secondary Preliminary Adequacy Issue #18
<br />Exhibit T - Environmental Protection Plan; Rule 6.4.20(14) [Rule 6.4.21(14) under the Hard
<br />Rock Rules effective Sept. 30, 2010], Geochemical Data and Analysis, page 14. In addition to
<br />the Acid-base accounting and SPLP analyses, the applicant is required to submit one sample of
<br />tailings for a long-term humidity cell test under ASTM method D5744-07. The sample to be
<br />submitted shall be selected in consultation with DRMS. The test shall commence as soon as
<br />possible and continue for the life of the project or until permission is received from DRMS to
<br />discontinue the test. Specific parameters of the test are shown in the table below. As the long-
<br />term results of these humidity cell tests will have a bearing on the technical practicability of the
<br />underground disposal option, the operator should commence the test as soon as possible. The
<br />Division will not allow any permanent underground disposal of tailings until at least one year's
<br />worth of data have been produced from the humidity cell test.
<br />The following table provides the humidity test protocols for analytes and frequency of analyses.
<br />The operator must refer to ASMT method D5744-07 for the required testing methodology. As
<br />this is a standardized ASTM test, there are certified laboratories available that have the capability
<br />and expertise to conduct this type of test.
<br />Week Parameters Frequency
<br />0 pH, alkalinity, sulfate, Ca, Fe, K, Mg, Na, Al, As, Zn
<br />1 pH, alkalinity, sulfate, Ca, Fe, K, Mg, Na, Al, As, Zn
<br />2-20 pH, alkalinity, sulfate, Ca, Fe, K, Mg, Na Every 2 weeks
<br />2-20 Al, As, Zn Every 4 weeks
<br />20-52 pH, alkalinity, sulfate, Ca, Fe, K, Mg, Na Every 4 weeks
<br />20-52 Al, As, Zn Every 8 weeks
<br />52+ pH, alkalinity, sulfate, Ca, Fe, K, Mg, Na, Al, As, Zn Every 8 weeks
<br />Response #18
<br />While Wildcat Mining will commit to conducting a humidity cell test (ASTM D-5744-7
<br />Wildcat Mining respectfully submits the need to prevent or delay the disposal of tailings
<br />underground based on readily available whole rock and water quality (including the fact
<br />historical mining activities have not adversely impacted water) is not technically justified.
<br />See Exhibit T (Environmental Protection Plan) for supporting information. Within 60
<br />days and as approved by DBMS, Wildcat Mining will initiate the humidity cell test.
<br />Revised
<br />4/14/2011
<br />32
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