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provides additional information further demonstrating why the Bulldog exploration <br />project does not qualify as a DMO. <br />1. Activities at Bulldog Mine currently consist of driving a decline toward the existing <br />underground workings and the mine pool. Driving the decline has the potential to <br />expose or disturb acid — or toxic- forming materials. <br />Multiple sources of evidence demonstrate that driving the exploratory decline will <br />not expose or disturb toxic or acid - forming materials as would be required to trigger <br />DMO status. See C.R.S. § 34- 32- 103(3.5)(a)(II). This fact is supported by the quality <br />and condition of existing waste rock at the site, historic geochemical data from prior <br />excavations at the Bulldog Mine and recent rock characterization undertaken by RGS, <br />which demonstrate that rock excavated during exploration activities is unlikely to be acid <br />generating and will have a high neutralizing potential. See Exhibit A, Western <br />Exposure, LLC, Preliminary Bulldog Waste Rock Characterization Report (March 25, <br />2013). <br />2. After intercepting the workings and mine pool, and in order to continue to <br />proceed toward potential mining and milling, reasonably anticipated activities will <br />include dewatering and water treatment because mining operations have the <br />potential to affect the hydrologic balance in both quality and quantity. The water <br />treatment facility likely will utilize acid or toxic chemicals to treat water that may <br />be affected by acid- or toxic - forming materials that were exposed or disturbed as <br />a result of mining operations. <br />DRMS's Notice fails to explain how potential future water treatment activities <br />justify DMO designation at this time. To trigger DMO status based on chemical usage, <br />the Bulldog exploration project must be a "mining operation" at which "[t]oxic or acidic <br />chemicals used in extractive metallurgical processing are present on- site." C.R.S. 34- <br />32-103(3.5)(a)(I). The Rules similarly require that such chemicals be "used in <br />metallurgical processing" to justify DMO status. Rule 1.1(14)(a). Any chemicals used in <br />a future water treatment plant to manage water produced during exploration activities <br />would be contained within the water treatment plant, used as part of the treatment <br />process only, and would not be utilized for metallurgical processing. <br />In any event, the currently approved exploration activities do not include <br />treatment and discharge of mine water. The exploration decline will intercept the <br />historic Bulldog Mine workings at elevation 9360, and will not intercept the mine pool. <br />The current mine pool water level is at approximately elevation 9240, approximately 120 <br />feet below the 9360 elevation level. Any future, expanded exploration that may require <br />the pumping of mine water is yet to be determined. While RGS has undertaken <br />