2019-08-23_GENERAL DOCUMENTS - M2018051

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Peter Hays August 23, 2019 Page 3 several monitoring wells would be installed during the "construction phase" for the project. That phase is expected to last from eight to twelve months. In order to get a useful data set about baseline groundwater levels and gradients and water quality conditions, the monitoring wells need to be installed at the beginning of the "construction phase," and data collected at least twice per month for an entire year before any mining begins. In addition, BMS has committed in the amended permit application to keep its mining and reclamation activities at least two feet above the groundwater table. It appears that BMS will be relying on the data from the monitoring wells to ensure compliance with this commitment. Under these circumstances, BMS should be required to collect data from the monitoring wells at least twice per month during the "life of the mine" (as opposed to the quarterly data collection proposed in the amended permit application). In addition, as this data collection is being done to address concerns raised by Bijou about impacts to its water rights, BMS should be required to share the collected data with Bijou. As mining will be taking place on a daily basis, collection of data once every three months is not sufficient. Bijou has suggested to BMS that transducers be installed in the monitoring wells to assist with the data collection process, but is not clear about BMS's position on that item. A commitment from BMS to operate as described in this section is a necessary part of any permit approval. Water Quality Impacts Bijou raised concerns about potential water quality impacts to Empire Reservoir in its May 9, 2019, letter. Recognizing that areas of the mining footprint will be in a state of flux during the mining operations, Bijou believes that BMS should take measures at the "permanent" areas of the mine site (parking areas, equipment storage areas, fueling locations, etc.) to prevent the introduction of hydrocarbons into the soil. This goal would likely be best achieved by paving these areas. It is not clear to Bijou from the amended permit application what areas of the Lost Creek Mine site would (or might) be paved.