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3) DRMS 15t adequacy letter for CN -01 to May Day Idaho Mine Complex, M -1981 -185, March 15, 2011, page 8, item
<br />30; and
<br />4) DRMS 3 adequacy letter for CN -01 to May Day Idaho Mine Complex, M -1981 -185, May 3, 2011, page 12, item
<br />30.
<br />The DRMS position is based on the available information, which indicates the seep to be drainage from the pre -law and
<br />collapsed Idaho #1 Adit, that there is a documented seep in close proximity to the collapsed portal (immediately in front of
<br />and in direct line with the portal), the local geology, and underground mine maps. Additionally, documents submitted by
<br />Frank Hagar and the Court Order for Case #06CW93, submitted by the Wildcat Mining Corporation as part of CN -01, also
<br />characterize the seep as mine drainage.
<br />The Division has reviewed the data you submitted regarding the chemistry of the water from the mine portal. Although in
<br />general, based on the data, the water appears to be of "good quality ", there are still some potential issues. For example, the
<br />total recoverable arsenic standard for the receiving stream segment is 0.02 ug /1, and based on the available information, the
<br />mine discharge does not meet this standard without treatment or dilution of the receiving stream (assuming dilution could be
<br />granted). Additionally, the stream segment to which the facility would discharge is reviewable and therefore subject to an
<br />antidegradation evaluation. The antidegradation evaluation would result in significantly more stringent permit limitations
<br />that would need to be compared to the discharge data. The data for several parameters shows that these limitations may not
<br />be able to be met without treatment or dilution of the receiving stream (again assuming dilution could be granted).
<br />Therefore, it is the Division's position that an individual NPDES discharge permit must be obtained for the discharge
<br />from the mine portal and any other non - stormwater discharges from the site. This discharge may not be covered
<br />under the existing or pending stormwater permits.
<br />The two individual permit applications on file that were submitted in January of 2010, for both the Mayday and Idaho Mine
<br />sites, were submitted and signed by Mr. Clements for the Wildcat Mining Corporation. These applications were deemed
<br />incomplete and this was communicated to the individual who submitted the applications. Updated information was received
<br />in April of 2010, although some information was still missing at that time. This has been communicated to the consultant
<br />working for Wildcat Mining, and has also been communicated to Mr. Neuman via communication with the permit writer. As
<br />these applications were submitted by a previous owner who is no longer associated with this facility, and no additional
<br />information has been submitted for over one year, the Division will not be taking any further action on these permit
<br />applications and will not be issuing permits based on these applications. The cases associated with these permit applications
<br />are considered closed.
<br />New, complete applications, signed and submitted by the current owner of the mine site will need to be submitted to
<br />the Division in order to properly permit this mining facility for discharge to waters of the State of Colorado. The
<br />application forms can be obtained on our website at www.coloradowaterpermits.com
<br />If you have any questions regarding this matter please feel free to contact me directly at 303 - 692 -3655, or via email at
<br />andrew.neuhart@state.co.us
<br />Sincerely,
<br />Andrew Neuhart
<br />Assessment Based Permits Unit Manager
<br />Water Quality Control Division
<br />CC: Annette Quill, AG Office (email)
<br />Kathy Rosow, WQCD Stormwater (email)
<br />Erin Scott, WQCD, Permits (email)
<br />Tony Waldron, DRMS — Denver (email)
<br />Wally Erickson, DRMS — Durango (email)
<br />Mike Harris, WQCD Enforcement Unit (email)
<br />George Robinson, R Squared, (email)
<br />Permit Files: COR040253, COR040252, C00048402, C00048399, COR040222
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