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Mr. Michael Cunningham 5 <br />CDRMS <br />December 13, 2013 <br />The State Engineer indicated that it is possible to permit proposed MW -3 for monitoring <br />purposes. UMC obtained a permit application from the State Engineer, and will submit this <br />application upon approval by the Division. <br />UMC will not use MW -3 as long as it is not permitted and we do not have water rights. <br />5. The Applicant has submitted surface and ground water monitoring data from the EPA <br />Region V111 California Gulch Group, which has been collected as part of the remediation <br />efforts for the California Gulch Superfund Site. The Division has reviewed the EPA's surface <br />and ground water data and has concluded that any baseline data to be used for the mill <br />should be site specific and collected as close as possible to the mill site. The Division will <br />require the Operator to collect five quarters of data from both of the ground water monitoring <br />wells. Baseline conditions of ground water quality will be established from the first five <br />quarters of data collected. Baseline conditions for surface water quality will be established in <br />the same manner. Please respond. <br />Response: <br />UMC believes that the extensive water quality data collected by EPA over the years <br />uniquely provides the Project will an understanding of regional ground water conditions that <br />would not otherwise be known had our project been located elsewhere. These data we <br />believe, at a minimum, provide an initial baseline water quality requirement that can be <br />supplemented by our own up- and down - gradient monitoring wells once we commence <br />production. <br />A concentrated area of stream flow from which to collect a surface water sample does not <br />exist on the property. Our only chance of capturing surface water samples is during or <br />immediately after an event where sufficient precipitation allows for flow through the <br />unnamed tributary. The unnamed tributary is very shallow and indistinguishable in certain <br />areas of the property. We established our surface water monitoring point in the deepest part <br />of the tributary, but have not been able to collect samples over the past 6 quarters. We will <br />be more successful in collecting samples once the plant is in operation and personnel are <br />on -site on a regular basis. <br />Please contact myself or Holly Michael for additional information or clarification to this submittal. <br />We may be reached by phone at 303 -947 -3499, nmichael@unionmilling.com for myself or 303- <br />947 -7837, hmichaelCunionmilling.com for Holly. <br />Si y, <br />Nick Michael <br />Member <br />Union Milling Company, LLC <br />Attachments <br />