|
Erickson, Wally
<br />From:
<br />Sent:
<br />To:
<br />Cc:
<br />Subject:
<br />ittiLiZAVigmao '
<br />JUL 11 2011
<br />Division of Reclamation,
<br />Mining and Safety
<br />Pineda, Loretta
<br />Thursday, July 07, 2011 11:13 AM
<br />'ptate2011 @gmail.com ; 'TateP @gtlaw.com ; 'NeumannC @gtlaw.com';
<br />': georgerobinson @R2INCORPORATED.COM'; 'L2change @aol.com
<br />'randalloser @gmail.com'; 'danielmadruga @cicassoc.com'
<br />Waldron, Tony; 'Jeff Fugate; Erickson, Wally; Shuey, Steve
<br />FW: Wildcat Mining Corporation -A few clarifying points.
<br />1
<br />LL
<br />C�a�( Cewxnavnic,kf is t
<br />From bi2M5 barecfor �
<br />Tu vJatrlcaf M,aang f rporx+rc& fr(Si-f8S
<br />M y b rd4l,o Mine C M-
<br />CN -01
<br />Penfield - We need an extension letter by 2pm today to move this project to the September Board Meeting. Thank
<br />you.
<br />DRMS has reviewed the four recent emails from R Squared, one sent on July 5, and three on July 6, 2011, submitted on
<br />behalf of Wildcat Mining Corporation (Wildcat). The following observations for your consideration:
<br />Joint Stipulation: Pursuant to the Joint Stipulation between Wildcat and DRMS, Wildcat must submit all
<br />responses to DRMS adequacy issues two weeks prior to the staff recommendation deadline. Current staff
<br />recommendation deadline is July 20, 2011. Therefore, Wildcat's deadline for responding to DRMS adequacy issues is
<br />July 6, 2011. During the June 29, 2011, meeting with Wildcat, Wildcat requested extension of the July 6 deadline to July
<br />11, 2011, but did not commit to extending the review period. During the June 29 meeting, DRMS responded that on July
<br />6, 2011, Wildcat must inform DRMS whether Wildcat intends to respond to all adequacy issues no later than July 11,
<br />2011, or request extension of the August 10 -11, 2011 MLRB hearing. As of the time of this email communication,
<br />Wildcat has not informed DRMS of its intensions to either hold with the current schedule or extend the review period.
<br />Response to issues raised by R Squared in the email sent July 5, 2011 at 2:09 p.m., "Subject: Wildcat Mining Corporation -
<br />A few clarifying points."
<br />1. In previous DRMS adequacy letters we have informed Wildcat that the augmentation pond constitutes affected
<br />land and must be located within the boundary of affected lands. We have identified the pond as an
<br />Environmental Protection Facility for which certified engineering plans are required. The current reclamation
<br />plan indicates removal of the augmentation pond during final reclamation. The augmentation pond is an
<br />essential component of the mining /milling operation and is clearly affected lands. See DRMS adequacy issues 6,
<br />7, 14(b), and 40 of the Preliminary Adequacy Issues, dated March 15, 2011; and DRMS adequacy issues 3(b), 5,
<br />8, 9, 14(b), and 40 of the Third Adequacy Letter, dated May 3, 2011.
<br />2. The discharge from the pre -law Idaho 1 Adit is a monitoring point for the DRMS permit. The augmentation pond
<br />will be filled from the mine discharge. DRMS must require Wildcat to monitor any /all discharges from the
<br />augmentation pond regardless of WQCD requirements. WQCD has informally indicated a CDPS permit will be
<br />required for the discharge associated with the Idaho 1 Adit. Due to the proposed underground disposal of mill
<br />tailings, DRMS is concerned a potential exists for perpetual water treatment liability. In the Preliminary
<br />Adequacy Issues, dated March 15, 2011, adequacy issue 30; and Third Adequacy Letter, dated May 3, 2011,
<br />adequacy issue 30, DRMS informed Wildcat of its concern and, pursuant to Rule 3.1.6(1)(b), required Wildcat to
<br />either obtain a CDPS permit, or a letter from WQCD stating a CDPS permit is not required. Wildcat has not
<br />obtained a CDPS permit for the mine discharge and has not provided a letter from WQCD stating a CDPS permit
<br />is not required.
<br />3. Access roads, whether permanent or temporary, if pre- existing and not substantially upgraded to support the
<br />mining operation are not defined as affected lands. The application does not propose to upgrade the existing
<br />access road across USFS lands. Therefore, the existing USFS route is not identified as affected lands and is not
<br />required to be located within the boundary of affected lands. Apparently, Wildcat interprets their temporary
<br />USFS permit to exclude other regulatory agencies and /or emergency access by Fort Lewis Mesa Fire District. Not
<br />sure what Wildcat is asking regarding the temporary access route across USFS lands.
<br />
|