2011-10-11_PERMIT FILE - M2011040

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Memo to G.R. Means 3 12 September 2011 Review of 110(d) Application File No. M -2011 -044 baseline data as required under Rule 6.4.21(9)(b) may possibly be done concurrently with mining activity after Division approval. The analyte list for ground water sampling must include every constituent in Tables 1 and 2 of the Colorado Water Quality Control Commission Regulation No. 41, The Basic Standards for Ground Water, with the following exceptions: Biological Parameters, Asbestos, Cyanide, Nitrate, Nitrite (the combined Nitrate + Nitrite analysis is sufficient), Chlorophenol, Color, Corrosivity, Foaming Agents, Odor, and Phenol. The analyte list must also include Vanadium, Phosphorus and Hardness. Temperature, pH and Conductivity must be measured in the field, and the ground water level should be measured prior to purging and sampling. 8) Rule 6.4.21 Exhibit U — DMO EPP: Section U(10.a) Waste Rock Geochemical Analysis. The Applicant should consult with the Division before conducting any geochemical tests or any water monitoring program to obtain pre- approval of the test and the analytes. Failure to do so may result in the testing parameters not meeting Division requirements, the data being rejected, and possibly having to repeat portions of the tests. The Applicant is advised that geochemical testing will be an ongoing program. The Applicant must commit to ongoing and periodic geochemical testing of ore and waste of run -of -mine rock at a rate to be approved by the Division. Based on the current mine plan, the Division recommends collecting sample suites for geochemical characterization of both ore and waste at a rate of approximately every 50,000 tons of waste rock produced, or yearly, whichever occurs more frequently. The material must be subjected to Whole Rock analyses and SPLP testing. The SPLP analyte list must include every constituent listed in bullet 7 above, plus the physical parameters pH and Conductivity. The Applicant must also commit to sampling any seepage that might arise from ore storage or waste rock piles, and the analyte list must be as stated above. The parameters pH and conductivity must be measured in the field at the time of sampling. 9) Rule 6.4.21 Exhibit U — DMO EPP: Section U(8.e) Surface Water Quality and Monitoring Plan. The Applicant should check that they are using the most recent version of Regulation 35. There are some discrepancies between the Applicant's table and the regulation (e.g., nitrite, dissolved oxygen, pH). 10) The surface water analyte list provided in Attachment U.8.4 is incomplete. The surface water sampling analyte list must include every constituent in Tables I through III of the Colorado Water Quality Control Commission Regulation No. 31, The Basic Standards and Methodologies for Surface Water, with the following exceptions: Biological Parameters, Total Residual Chlorine, Cyanide, Sulfide, and Asbestos. The analyte list must also include Vanadium, Phosphorus and Hardness, and the physical parameter Conductivity. Temperature, pH, and Conductivity must be measured in the field.