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Whetstone Associates Technical Memorandum sumps, and Ralston Creek were analyzed for phosphorous in the past, phosphorous results were below detection in 100% of the samples analyzed. 8) The statement on pg. 9-3 that the drinking water standards are not considered to be directly applicable to the alluvial monitoring wells or to groundwater in the underground void because these are not direct sources of drinking water supply is not appropriate. The mine pool and local alluvium are directly linked to drinking water sources. The Operator must design mitigation strategies with the drinking water standards as the target. Drinking water standards are not the appropriate standard to be applied within the alluvium. Drinking water standards are applied at the point of compliance which, by definition, will take into account potential exposure pathways to humans. "Point of Compliance" in the Mineral Rules and Regulations of the Colorado Mined Land Reclamation Board for Hard Rock, Metal and Designated Mining Operations is defined as follows: "Point of Compliance " means locations down-gradient of the facility or activity at which water sampling may be conducted to demonstrate compliance with applicable groundwater standards established by the Water Quality Control Commission, or permit conditions required by the Office or Board to measure compliance with the MLRB permit. Mitigation strategies for groundwater in the alluvium and fill are designed to meet the uranium standard of 0.03 mg/L. Interim mitigation strategies include the 50-gpm ion exchange water treatment system which went online July 2, 2010 and the 100-gpm water treatment system which is scheduled to begin operation by July 31, 2010. Both of these pump-and-treat systems are designed to meet the 0.03 mg/L uranium discharge standard. The long-term sustainable mitigation options are also being designed to meet the 0.03 mg/L target for uranium in surface water in Ralston Creek. The text on page 9-3 of the EPP has been revised to include the new uranium standard of 0.03 mg/L. 9) Operator states in footnote 15 on pg. 9-4 ".... uranium concentrations in excess of the ground water standard reported by the lab for up gradient monitoring well MW00 are questionable.... " Please elaborate on why the data are questionable. Further evaluation of spreadsheet data from multiple sources, including the original laboratory electronic data deliverables (EDDs), confirms the potentially "anomalous" uranium values for monitoring well MW00. The Operator is reviewing paper files to locate the original laboratory data sheets and will forward them to DRMS when available. The data of interest was collected in 2002 (2 samples), 2005 (1 sample) and 2006 (3 samples), when experienced environmental professionals at the mine were routinely conducting samples and the analytical laboratory was performing complete quality assurance/ quality control program. There is no reason to believe that sample bottles were mislabeled or that there is any laboratory error. The results that were elevated above the uranium standard in the background well occurred in clusters (e.g., three consecutive quarterly samples in 2006) as opposed to a single isolated outlier. Whetstone wrote the footnote saying, "Although uranium concentrations in excess of the groundwater standard reported by the lab for upgradient monitoring well MW00 are questionable, 4109C.100731 5