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To: Jared Ebert <br />Date: February 14, 2018 <br />Page 14 <br />i. Proposed groundwater sampling locations and frequency, including up-gradient <br />background location(s) and points of compliance. Quarterly water quality <br />sampling would be sufficient. Please include sampling of the water in the water <br />management pond during operations as it will directly recharge groundwater in <br />the vicinity. <br />ii. Please include a description of the method of monitoring well completion. <br />iii. Sampling protocol(s) and analytical methods/detection levels, and quality control <br />and quality assurance methods. <br />iv. Appropriate analyte list. At a minimum the full Reg. 41 Table 1 Inorganic <br />Analytes list should be collected for establishing background levels and used for <br />regular monitoring parameters. Asbestos may be eliminated, however, TDS,pH, <br />and iron should be included. <br />v. Please commit to submitting the results of water monitoring sampling during the <br />mining operation and reclamation to the Division with the annual report each <br />year. <br />vi. Please specifically state the formation, aquifers or strata to be sampled. <br />vii. Baseline Water Quality Data. Please provide baseline water quality data to <br />document the pre-mining water quality based on the analyte list noted above. The <br />applicant will need to collect at a minimum five quarters of water quality data <br />prior to exposing groundwater and/or initiating dewatering operations. The <br />Division may consider conditionally approving the application with a <br />commitment from the Applicant that they will collect and submit the baseline <br />water quality data prior to exposing groundwater and/or initiating dewatering <br />operations. <br />Response 39b <br />The attached Groundwater Sampling and Analysis Plan (Attachment 3) addresses the <br />comments above. <br />Comment 40a <br />Regarding the item discussed above,please provide a rational and any applicable data to <br />substantiate the claim that groundwater quality will not be an issue. <br />Response 40a <br />See previous response and section 5.5.3 of the revised groundwater report. <br />Comment 40b <br />Please see item number 39 above. <br />Response to DRMS Adequacy Review 3 comments TELE ST 0