2019-05-09_PERMIT FILE - M2018051 (3)

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Peter Hays May 9, 2019 Page 6 implemented prior to any mining permit or reclamation plan being approved' to collect groundwater data in the area of, and adjacent to, the proposed mining footprint. If a permit is approved, the monitoring should also be done routinely as part of the mining and reclamation process. The monitoring plan would include, at minimum, the following concepts: ■ Drill and construct a series of monitoring wells across the entire saturated thickness of the alluvial aquifer to bedrock to establish baseline conditions and to monitor seasonal trends in water levels in relation to changes in storage for Empire Reservoir. o In concept, a number of monitoring wells would be completed along the east/northeast boundaries of the mining footprint, generally placed in an alignment from southeast to northwest with enough offset to facilitate development of a potentiometric surface map between Empire Reservoir and the mining project. o Monitoring wells would be constructed to facilitate both long-term monitoring of groundwater levels and for tracking of potential water quality degradation (see discussion below). ■ Establish baseline alluvial groundwater levels and water quality. ■ Evaluate local groundwater gradients in relation to Empire Reservoir operations. ■ Confirm local bedrock elevations between Empire Reservoir and the proposed . mining footprint. • Evaluate the potential for seepage from the mine site into Empire Reservoir, and from Empire Reservoir to the mine site. Along with monitoring aquifer water levels, BMS should also be required prior to any mining permit being approved to conduct water monitoring of the area in which mining and reclamation is proposed to better determine the local hydraulic gradients, and to establish ambient groundwater quality. If a permit is approved, BMS should be required to conduct consistent, long-term monitoring to ensure that the mining operations and reclamation do not create water quality impacts to the alluvium and to Empire Reservoir, and to remedy any impacts in a manner and timing to prevent injury. Bijou also believes that more information is needed explaining how stormwater and I It is Bijou's understanding that a groundwater monitoring plan is supported by State water administration and dam safety personnel.