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To: Jared Ebert <br /> Date: February 27,2018 <br /> Page 3 <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 <br /> comment 39b. <br /> Comment 39c <br /> The Division has reviewed the Groundwater Sampling and Analysis Plan included in <br /> Attachment 3 of the adequacy review response. Please address the following items: <br /> i. Regarding water quality sampling,please add MW-13 to the groundwater quality <br /> sampling plan. <br /> ii. Upon further review of Regulation 41, regarding the Interim Narrative Standards, <br /> please add the following analytes to the analyte list and the sampling matrix as <br /> appropriate(units are mg/L): <br /> 1. Aluminum 5.00 <br /> 2. Boron 0.75 <br /> Response to DRMS Adequacy Review 3 comments TEL E S T <br />