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Mr. Thomas A. Schreiner <br />April 29, 2007 <br />Page 7 <br />therefore an appropriate point of compliance location to monitor mine-related <br />impacts to groundwater during mining operations. <br />The post-closure groundwater piezometric surface in the vicinity of the Cash <br />Mine is expected to be a muted reflection of the surface slope, with a gradient of <br />approximately 0.2 directed to the southeast. Accordingly, the proposed location <br />of MW-5 has been selected to be directly downgradient of the post-closure <br />mining, and is considered to be an appropriate point of compliance for post- <br />closure monitoring of groundwater impacts. <br />POST-CLOSURE CONDITIONS <br />Comment <br />6. The Operator notes in Attachment 1 -Groundwater Modeling of the Water <br />Monitoring Plan that under Post-Closure conditions, the water level will increase <br />until seepage emerges from the #1 Level adit area consistent with historic 'pre- <br />law" conditions, and not emergent as a point source discharge. Please note that <br />the approved mine and reclamation plan specifies a "zero discharge facility" <br />during mining as well as final reclamation. As previously stated in the Division's <br />Amendment No. 2 "2nd Adequacy Review Comments" the operator will be <br />required to obtain an NPDES Water Quality Discharge Permit from the Water <br />Quality Control Division, Colorado Dept. of Health in the event of any discharge <br />from the Mount Royal Adit #1 at any time during mining and/or final reclamation. <br />However, if the operator has any written correspondence from the Water Quality <br />Control Division, Colorado Dept. of Health to the contrary, please provide. <br />Response <br />Comment noted. MRV does not have contrary correspondence from Colorado <br />Department of Health. Based on information regarding conditions of the <br />collapsed #1 Level adit prior to construction of the #3 Level adit MRV does not <br />expect any discharge to surface waters from the #1 adit during operations or post <br />closure. <br />Respectfully submitted, <br />Adrian Brown, P.E. <br />Adrian Brown Consultants, Inc. <br />cc: Mr. Matt Collins, Mount Royale Ventures, LLC. <br />