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r r <br /> COLORADO LEGACY LAND <br /> As part of the on-going due diligence for system integrity the operator proposes two physical inspections to be <br /> performed on a quarterly basis. It is recommended that the operator conduct a physical pipeline walk to visually <br /> inspect the total run of the mine pump effluent line in to witness any type of small leak or potential weak spot that <br /> could become a leak. It is also recommended that the operator conduct a compressed air pressure test that will <br /> determine pipeline pressure integrity and in turn a break in the line. In both instances these steps will assist in <br /> eliminating line inadequacies not witnessed in the previously mentioned instrumentation controls. <br /> Comment 3: Table 1. Proposed Quarterly Sampling Suite indicates total Boron is not a part of the approved <br /> surface water sampling suite.A review of the Environmental Protection Plan(EPP) shows that total Boron is to <br /> be included in the surface water sampling suite. Please ensure that surface water sampling events includes <br /> analysis for total Boron. <br /> Response: The requested revision has been made. Table 1 of Technical Revision 27 has been revised to include <br /> analysis for total Boron,consistent with the EPP. <br /> Comment 4: Table 1. Proposed Quarterly Sampling Suite indicates dissolved uranium is not a part of the <br /> groundwater sampling suite. A review of the EPP shows that dissolved uranium is to be included in the <br /> groundwater sampling suite. Please ensure that groundwater sampling events include analysis for dissolved <br /> uranium. <br /> Response: The requested revision has been made. Table 1 of Technical Revision 27 has been revised to include <br /> analysis for dissolved uranium,consistent with the EPP. <br /> Comment 5:The Operator is proposing to eliminate certain analytes from the surface and groundwater sampling <br /> suites. The Operator's technical justification for eliminating certain analytes includes duplication of analytes <br /> between sampling suites,non-detect analytical results,and analytical results which are below applicable surface <br /> or groundwater standards.The Schwartzwalder Mine is a dynamic site with respect to water quality treatment <br /> and the mine pool chemistry.Upon approval of this Technical Revision the Operator will proceed to manage the <br /> mine pool in a different manner than it was historically managed. In addition, the Operator is currently <br /> excavating waste rock from the valley floor.The Division expects to see changes to the surface and groundwater <br /> quality as a result of these activities. <br /> A condition of the transferring the Reclamation Permit from Cotter Corporation to Colorado Legacy Land, <br /> requires the submittal of an amendment application which includes the site wide conceptual model and provides <br /> a plan addressing the physical and chemical stabilization of the mine pool and specifically addresses the <br /> concentrations of dissolved uranium and other constituents as required under the conditions of the permit.The <br /> condition also requires notification to Denver Water and the City of Arvada,who have an interest in participating <br /> in the review of the site wide conceptual model. <br /> Therefore,the Division believes that it would be premature to remove any analytes from the sampling suite at <br /> this time for the above stated reasons.A reduction of the sampling suite would be warranted upon approval of <br /> the required amendment or upon a demonstration the site is stable with respect to surface and groundwater <br /> quality. In order to approve the proposed Technical Revision,the Division requests the Operator withdraw the <br /> modifications to the sampling suites from consideration under TR27.Please respond. <br /> Response: The requested revision has been made. Technical Revision 27 have been revised so that no groundwater <br /> or surface water sample analyses are removed. Quarterly surface water and groundwater samples will be collected <br /> for analytes show in Table 1. <br /> PAGE 3 OF 3 <br />