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Response to Preliminary County Comments Received on March 17, 2011 <br />Point of Compliance <br />The point of compliance for groundwater will be at the monitoring well to be located at the <br />May Day No. 2 bench. Groundwater monitoring wells may be completed if groundwater is <br />encountered during future exploration activities. The point of compliance for surface water <br />will be SW-2 located down gradient of the mine site and located on La Plata River. <br />Adequacy Issue #38 <br />Attachment T-6 provides parameters and detection limits for analysis of surface water samples. <br />However, some of the parameters listed on Attachment T-6 indicate analysis for dissolved <br />metals, suggesting a ground water sample. Please provide a separate list for surface and ground <br />water parameters. As noted above, please ensure the list of ground water parameters includes the <br />full suite of parameters listed on Table 1 through 4 in CDPHE Regulation 41, Basic Standards <br />for Ground Water. For surface water sampling, the Division requires all parameters on Tables I <br />through III of CDPHE Regulation 31, Basic Standards and Methodologies for Surface Water. If <br />the Applicant desires a variation from the full suite of parameters and detection limits listed in <br />either Regulation 31 or 41, please submit such request for Division review. <br />Response #38 <br />Suggested surface and groundwater monitoring modifications have been added to the <br />existing monitoring program as of April 18, 2011. <br />Adequacy Issue #39 <br />Pursuant to Rule 6.4.21(10)(a), please provide design specifications certified by a licensed <br />professional engineer for all Environmental Protection Facilities intended to hold, convey, <br />contain, or transport designated chemicals, including process solutions and mill tailings <br />containing designated chemicals. Please ensure the certified designs address the redundant <br />containment measures required under Rule 6.4.21(7)(e). <br />Response #39 <br />Suggested modifications are incorporated in the existing mine plan. ASTM approved <br />containers, tanks, pipes, drums, and vessels will be used on site. Liquids and designated <br />materials will be designed with secondary containment as specified in Exhibit U. In <br />addition all materials will be transported, stored and disposed in accordance with the <br />commitments made in Exhibit D and U. <br />Adequacy Issue #40 <br />Please provide design specifications certified by a licensed professional engineer for all <br />Environmental Protection Facilities intended to capture and/or retain surface water run-off from <br />Revised <br />4/14/2011 <br />23