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Mr. Michael <br />AM -01 Application Adequacy Review <br />July 1, 2013 <br />File No. M -1990 -057 <br />Operator has only collected one ground water sample from MW -1 since 2009. As noted <br />above, the Division has identified two domestic wells which are on the adjacent properties to <br />the west of the mill. These two wells are completed in the same unconsolidated glacial <br />outwash and range in depth from 75 to 100 feet deep. <br />Currently MW -1 serves as the compliance point for the mill site. Since MW -1 is not of <br />sufficient depth to reach the aquifer which the two nearby domestic wells are completed in, it <br />is not reasonable to assume that sampling MW -1 will capture potential impacts to this <br />aquifer. Therefore, the Division will require the applicant to deepen or replace MW -1 to a <br />depth which will allow for consistent sampling of the alluvial aquifer. Please respond. <br />The Division has determined that in addition to MW -1 at least one more well will be required <br />to adequately capture the down gradient ground water flow which could potentially impact <br />the adjacent domestic wells. The Division will require the Operator to install a second well <br />on the west side of the TSF. The well should be located as close as possible to the western <br />permit boundary and should be completed in the alluvial aquifer. Please respond. <br />5. The Applicant has submitted surface and ground water monitoring data from the EPA Region <br />VIII California Gulch Group, which has been collected as part of the remediation efforts for <br />the California Gulch Superfund Site. The Division has reviewed the EPA's surface and <br />ground water data and has concluded that any baseline data to be used for the mill should be <br />site specific and collected as close as possible to the mill site. The Division will require the <br />Operator to collect five quarters of data from both of the ground water monitoring wells. <br />Baseline conditions of ground water quality will be established from the first five quarters of <br />data collected. Baseline conditions for surface water quality will be established in the same <br />manner. Please respond. <br />As previously mentioned, if you are unable to provide satisfactory responses to any inadequacies <br />prior to August 2, 2013, it will be your responsibility to request an extension of time to allow <br />for continued review of this Technical Revision. If there are still unresolved issues when the <br />decision date arrives and no extension has been requested, the Technical Revision will be denied. <br />If you have any questions, please contact me at (303) 866 -3567 x8116. <br />Sincerely, <br />&- I - <br />Michael A. Cunni gham <br />Environmental Protection Specialist <br />CC: Tom Kaldenbach, DRMS <br />