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rvr� Re-� <br />The Union Milling Company <br />P.O. Box 620490 <br />99" Littleton, CO 80162 -0490 <br />+1.303.947.3499 <br />19 December, 2013 <br />Mr. Michael Cunningham RFr, <br />Environmental Protection Specialist <br />Division of Reclamation, Mining and Safety DEC 19 2013 <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 Division of Keuan ation, <br />Denver, CO 80203 Mining & Safety <br />michael.cunninaham @ state.co.us <br />RE: Leadville Mill; M1990 -057, Amendment Review No.1 — Question 24 Response <br />Dear Mr. Cunningham, <br />Following is Union Milling Company's (UMC) response to Adequacy Review No. 1 question 24. <br />This completes our AR 1 responses. <br />24. The Reclamation Plan calls for conducting geochemical characterization of the tailings <br />prior to placement of the topsoil cap. Please specify the geochemical analyses the <br />Operator intends to conduct. <br />Response: <br />UMC will include the following text addressing geochemical characterization in the <br />Permit Document <br />Initial Testing <br />Prior to accepting each production run ( "Batch ") of toll ore ( "RoM ") to be treated at the <br />mill, UMC will require that it be tested to assure it meets pre- specified Acceptance <br />Criteria. For each Batch, Acceptance Criteria will include testing to assure that RoM: <br />A. Can be economically processed within the operating limits of the mill; and <br />B. Meets mill facility permitted conditions. <br />Acceptance testing will be performed by an independent laboratory before the RoM <br />arrives on -site. The process will be as follows: <br />1. Seller and Buyer agree to "Economic Terms ". E.g. payment based on RoM <br />grade, process recovery, market prices, treatment costs, etc. <br />2. Batch of RoM to be processed is identified. This may, for example, be a <br />specific stope in a mine, or a stockpile of RoM on the surface. <br />3. The Batch is surveyed to determine quantity and to collect a Representative <br />Sample. <br />