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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 #19 <br />Noted. <br />Adequacy Issue #20 <br />A. Adequate for now - more information pending. <br />Response #20 A <br />Noted. <br />B. The Division accepts the plan to conduct geochemical testing quarterly or every 5,000 <br />tons, whichever occurs first. Details of the types of testing are not presented. The <br />Applicant must commit to at least acid-base accounting with sulfur speciation, and whole <br />rock analyses of each set of samples. From these data it will be determined if kinetic <br />testing is also warranted. <br />Response #2011 <br />Comment noted. <br />See also Attachments M (response to Mr. Bird's adequacy questions, and revised Exhibit G <br />and Attachment T-5-1) and O (Water Quality Detection Parameters and Limits) to the <br />Response to Third Adequacy Issues. <br />Adequacy Issue #21 <br />Water information. There is potentially conflicting information in this section regarding the <br />Upper Jurassic Entrada Sandstone. Various tables in the report indicate that the unit has very low <br />to low transmissivity and that the hydrologic characteristics of the unit are "not significant in <br />Colorado." Elsewhere, the text refers to the Entrada as a "more permeable formation." The <br />literature suggest that the Entrada Sandstone in the San Juan Basin is a historic oil and gas <br />producer, thickness of nearly 400 feet locally, porosity up to 26%, and permeability in the mid- <br />range of silty sand (Freeze and Cherry, 1979; Halpenny and Harshbarger, 1950; Matheny and <br />Ulrich, 1983; USGS OFR 78-964; Wright and others, 1962). These characteristics suggest that <br />the formation has the potential to be hydrogeologically significant, and therefore the formation <br />should not be downplayed in the hydrogeologic conceptual model. <br />Response #21 <br />The May Day Idaho Entrada Sandstone is cemented and therefore the material has little or <br />no porosity or permeability except when the formation is fractured. These characteristics <br />6/6/11 <br />9