2011-09-16_REVISION - M1990057 (9)

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CDRMS question 14. As required by Rule 7.3.2(2), please commit to providing the Division with certified verification by a professional engineer or other appropriately qualified professional that will confirm that facility was constructed in accordance with the approved design plan. UMC Response UMC has retained an Owner's Engineer, who is a Registered Professional Engineer and a Professional Land Surveyor in the State of Colorado, to monitor the contractors. Additionally, as- constructed drawings will be provided and certified, by the same Owner's Engineer, that that the facility was constructed in accordance with the approved design plan. CDRMS question 15. The current Reclamation Plan states no final slopes will be steeper than 4H:1 V. However, the outslopes of the TSF will be reclaimed to 2.5H:1 V. Please clarify if the final slopes of the TSF will remain at 2.5:1 V. If so, then revise the Reclamation Plan accordingly. UMC Response The Phase 1 TSF facility will have reclaimed slopes of 2.5H:1 V. The Reclamation Plan will be revised to reflect this statement. CDRMS question 16. As required by Rule 6.2.1(2), all maps must be prepared and signed by a registered land surveyor, professional engineer, or other qualified person. In addition, outline and label the permit boundaries which correspond to the legal description; the Division considers the area bounded by the permit boundary to be analogous to the affected area. Please revise Exhibit TSF - 01 accordingly. UMC Response UMC is resubmitting TSF -01, TSF -02, TSF -03, TSF -04 and has added an additional Exhibit TSF -05. These exhibits are signed by a Colorado Registered Professional Engineer. J. Michael Elder, No. 15803, is licensed through December 31, 2012. The Exhibits show a red dashed line, marked disturbed area in the legend. This red dashed line is the permit boundary and the affected area boundary. The permit boundary and the affected area boundary are exactly the same areas. CDRMS question 17. To establish the amount of the required bond, it must be assumed that at the time of bond forfeiture, fluids will have filled the tailing impoundment to capacity, and that the fluids cannot be released into the environment. Please provide a plan and estimated cost for disposing of the uids. UMC Response UMC envisions no scenario where the above assumption for a completely fluid filled impoundment to be true. In the event of an immediate cessation of operations, approximately 350st of water would be in circuit and an equivalent amount of water in the decant portion of the impoundment. A 2ft depth of water would occupy an area approximately 100ft x 100 feet. Only storm water would additionally contribute to the water level in the impoundment, and in UMC's experience and based upon visual observations of the existing TSF impoundment constructed 20yrs ago, the evaporation rate far exceeds the storm inflow rate. UMC's opinion is that other than in the spring melt, there will be no water in the impoundment within M1990 -057 September 16, 2011