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Sixth Adequacy Letter, Amended CN -01 <br />May Day Idaho Mine Complex, M- 1981 -185 <br />a. Pursuant to Rule 3.1.6(1)(b), the Applicant /Operator is required to comply with <br />WQCD regulations. Pursuant to Rule 6.4.13, please revise Exhibit M, Other Permits <br />and Licenses, to affirmatively state the Applicant will pursue and obtain the <br />individual NPDES discharge permit required by WQCD. The available information <br />indicates the mine discharge from the Idaho No. 1 Adit is perennial. Therefore, a <br />potential for perpetual water treatment liability appears to exist and the NPDES <br />permit may have to address water treatment after reclamation has been completed. <br />b. Please revise Exhibit L, Reclamation Costs, to address all measures taken to assure <br />the protection of water resources, including costs to cover necessary water quality <br />protection, treatment and monitoring as required by the NPDES discharge permit <br />and the Act and Rules, pursuant to Rules 4.2.1(4) and 6.4.12. <br />13. In the Division's fifth adequacy letter, the Division indicated Exhibit G, Water Resources, <br />and Exhibit U, Environmental Protection Plan, had been reviewed by staff member David <br />Bird. Mr. Bird generated a technical review memorandum in which he identified <br />outstanding adequacy issues for Exhibit G and Exhibit U. Copy of Mr. Bird's technical <br />review memorandum, dated August 23, 2011, was attached to the Division's fifth <br />adequacy letter. <br />Mr. Bird has reviewed the Applicant's response to the adequacy issues identified in his <br />previous memorandum and has identified the following adequacy issues: <br />a. Response to Adequacy Issue No. C.4.: Be advised that addition of any acid or <br />base to a sample prior to analysis for paste pH, acidity, or alkalinity will <br />compromise the analysis. Section 1.1 of Method 305.2 states that the method is <br />"applicable to rain, surface and other waters of pH less than 8.3." The method is <br />not appropriate for solid media. DRMS recommends that the Operator measure <br />paste pH using Sobek method 3.2.2 and forego any attempt to measure acidity in <br />solids. The only sample preparation needed is grinding and screening to the <br />appropriate mesh. Rather than alkalinity in solids, DRMS recommends analysis <br />for acid - neutralizing capacity. <br />b. Response to Adequacy Issue No. E.3.a and b.: Within one year of permit <br />approval, Wildcat must provide all ground water level data collected from any <br />drill holes, and together with known spring elevations and stream elevations, <br />provide to DRMS a ground water elevation contour map. The map must be <br />updated through the mine life as new ground water level data are obtained. <br />Upon interception of ground water in drill holes, the operator must also perform <br />airlift recovery tests to obtain water production data. <br />c. Response to Adequacy Issue No. E.3.c.: Wildcat must begin collecting ground <br />water data from monitoring wells immediately following well development, and <br />well development must be concluded within five days of completion of the wells. <br />d. Response to Adequacy Issue No. B.: Although the cross - section "A" appears to <br />indicate that a diversion ditch will be constructed upslope of the augmentation <br />pond, the location of the ditch is not shown on the plan drawing. Please clarify. <br />Please address the adequacy issues identified by Mr. Bird. <br />9 <br />