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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 />without DRMS written approval. <br />D. The Applicant's statement that "surface and ground water quality have not been affected <br />by past mining activities" may not be accurate. Based on recent water quality data from <br />sample sites SW-1 and SW-2, the La Plata River displays noteworthy increases in the <br />concentrations of several constituents (Al, As, Cd, Fe, Mn, Ni, Pb) as it flows past the <br />mine site. These increases may be caused by ground water discharge that has been <br />adversely impacted by past mining activities. The environmental protection plan must <br />provide adequate protections against any further degradation of surface and ground water <br />quality. <br />Response 17 D: <br />Review of the existing database does not suggest a significant difference in SW-1 and SW-2 <br />La Plata Al, As, Cd, Fe, Mn, Ni, Pb water quality analytes. <br />Adequacy Issue #18 <br />DBMS appreciates the Applicant's willingness to commence the long-term humidity cell test <br />within 60 days. However, the timetable of the test will depend partly on the understanding of the <br />geochemical composition within the mine workings, which will remain mostly unknown until <br />access to the workings is gained. The Division wants the long-term humidity cell test to be <br />conducted on the material with the greatest potential to adversely impact water quality. If the <br />Applicant can say with confidence that such material is currently available, then the Applicant <br />has the option of starting the long-term test within the proposed 60 day timeframe on the <br />currently available material. However, the Applicant should be advised that if more appropriate <br />material (with potentially more adverse environmental impact) is discovered within the mine <br />workings, then the test may have to be re-started with the new material, or an additional separate <br />test initiated. The Applicant needs to understand that the depositional strategy for the tailings <br />cannot be finalized until the results for at least the first 20 weeks of the test are available. <br />Response #18 <br />Adequate information is available on currently available material without conducting long- <br />term humidity cell tests. The test results will not provide data that would or could alter the <br />decision to dispose dry stacked (non-leaching) in a dry underground environment. The <br />proposed operation eliminates driving forces to suggest that leachate would be generated or <br />available to influence surface or groundwater quality. The current leaching studies suggest <br />no water quality impacts will occur. <br />Adequacy Issue #19 <br />Adequate. <br />6/6/11 <br />8