2011-10-11_REVISION - M1981185

• Permit No: M1981185
• IBM Index Class Name: REVISION
• Doc Date: 10/11/2011
• Doc Name: Response to 6th adequacy letter to CN-01
• From: GreenbergTraurig for Wildcat Mining Corporation
• To: DRMS
• Type & Sequence: CN1
• Email Name: WHE
• Media Type: D
• Archive: No

Mr. Wallace H. Erickson
Response to Sixth Adequacy
October 11, 2011
Page 14
DEN 97,629,117v1 10 -11 -11
reclamation plans and maps, as necessary, through the
Technical Revision or Amendment process.
o After obtaining DRMS approval through the Technical
Revision or Amendment process, proceed with remainder
of work plan.
Wildcat is also submitting a revised Figure F -5A to clarify that the mine debris,
inappropriately placed in Little Deadwood Gulch and subject of Violation MV- 2010 -020
will be completely removed. See Ex. 5; see also Response to September 27 Cazier
Memo, Adequacy Issue No. 11.
Adequacy Issue No. 9.
Design specifications, certified by a licensed professional engineer, are required
for all Environmental Protection Facilities under Rule 6.4.21(10), including the redundant
containment measures required under Rule 6.4.21(7)(e). The Division had previously
clarified that such designs were required for the following structures:
• Mill building
• Storage sheds, including Zircon or large shipping containers, in which designated
chemicals are stored or utilized
• Location of dewatering of tailings
• Pipelines for tailings and recycled process water
• Recycled process water storage tanks
• Tailings disposal and/or storage locations
• Sump or pit to contain leachate from stacked tailings
The Applicant submitted design specification for several of the Zircon units
identified as Environmental Protection Facilities. The specifications are provided on
CLC drawings 06.10 and C6.11, and on Figure D -1 of Attachment D -2. On Figure D -1
of Attachment D2, the capacity of the secondary containment structure is claimed to be
2,350 gallons. Measurements taken from Figure D -1 of Attachment D -2 do not support
the stated capacity. Measurements taken from Figure D -1 of Attachment D -2 indicate the
capacity of the secondary containment structure is approximately 1,720 gallons. Please
clarify how the Applicant determined the containment capacity. Please support the
clarification with drawings of smaller scale and greater detail, as necessary for the
Division to verify the containment capacity.
The Applicant did not provide the specifications required by Rules 6.4.21(10) and
6.4.21(7), for the mill facility, tailings dewatering location, pipelines for transport of
tailings and recycled process fluids, storage tanks for recycled process fluids, process
fluids disposal locations, and the tailings disposal locations.
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