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Geochemistry and Water Quality Review Adequacy Response <br />Wildcat May Day; DRMS File No. M-1981-185 Conversion Application CN-1 <br />Response #7 <br />Comment noted. The Company has demonstrated the materials tested to-date to support <br />the permit application have not identified or tested hazardous or toxic producing materials. <br />Adequacy Issue #8 <br />A. The locations at which down-gradient impacts may reasonably be expected are not well <br />known, because the ground water system is not adequately characterized. The Division <br />should not approve the application until a baseline characterization plan and hydrologic <br />testing program are submitted that are adequate to meet the requirements of Rules <br />6.4.21(8) and (9). <br />B. The maps and figures provided with the application indicate at least 11 proposed drill <br />pads. Some of these are in locations that might be suitable sites for conversion to <br />monitoring wells or piezometers. <br />Response #8 <br />Wildcat Mining has characterized surface and groundwater quality based on existing <br />sampling points and has adequately characterized the geology of site for baseline purposes <br />using historical data in accordance with Rule 6.4.21(8)(a) and (b). The characterization <br />and regional setting is presented in Attachment J (Environmental Protection Plan) to the <br />Third Adequacy Response. Site characterization including surface and groundwater <br />monitoring will continue during exploration, mining and reclamation to provide <br />information to determine if the environmental baseline conditions have changed. Wildcat <br />Mining has presented several "white papers" with supporting water quality data which <br />discuss the rationale why the existing database adequately defines surface and <br />groundwater conditions. Wildcat Mining has advanced a proposal which describes a <br />phased surface and groundwater monitoring program in which it requests that DRMS <br />continue to evaluate quarterly water quality data presented by Wildcat Mining in order to <br />determine after another one or two quarters (the sixth and seventh quarters of sampling) <br />that Wildcat Mining has presented sufficient data necessary to adequately characterize <br />baseline conditions. Two wells will be drilled to provide additional groundwater quality <br />characterization. One well will be located near the historic Idaho Mill building and the <br />Idaho Spring, and the other adjacent to the May Day No. 2 mine bench. Wells will be <br />completed 30 feet below the elevation of the La Plata River. Each well will be completed, <br />tested, and sampled on a quarterly basis. See also Response #5 above. <br />Adequacy Issue 49 <br />Adequate. <br />6/6/11 <br />4