2021-06-17_PERMIT FILE - M2001046 (4)

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Page 3 Mr. Eric Scott June 4th, 2021 backfilled and revegetated for reclamation, and that all excavated cells will be mined to at slope no steeper than 3:1, H:V thereby eliminating the need to backfill to achieve final reclamation slopes. -DRMS understands that topsoil will be replaced at a minimum depth of 6"prior to revegetation. EXHIBIT F-Reclamation Plan Map(Rule 6.4.6): •DRMS acknowledges the oil/gas structure constrained reclamation configuration provided, and that the operator will submit Technical Revisions to modify the provided reclamation plan as needed if these structures are removed at some time in the future. •Please correct/revise the names of all monitoring wells to match the names used on the provided WL data spreadsheet provided. Names have been updated to reflect the water level spreadsheet.Monitoring wells 942 have been removed from the spreadsheet as these were drilled interior to the slung wall alignment and will be abandoned after passing the provisional leak test(See attached Monitoring Well Spreadsheet). EXHIBIT G-Water Information(Rule 6.4.7): The following information is still required for Exhibit G: •Sampling and Analysis plan describing how the operator will document ambient groundwater conditions relative to Tables 1-4 of the Interim Narrative Standard prior to mining, as well as insure/document that the water quality will meet the Interim Narrative Standards during operation and prior to release. To document ambient groundwater conditions prior to mining,RMCC collected samples from Nix- Owens-MON 4, Nix-Owens-MON 5, Nix-RMCC-MON 6, Nix-RMCC-MON 7,and Nix-RMCC-MON 8 on June 3,2021.These wells were selected to provide background water quality data along each roadway and the Varra pit.The analytes listed on Tables 14 of the Interim Narrative Standards, excluding the radiological section,were tested for in each of the wells sampled.The lab results from this analysis will be included with the next annual report for the site.A list of analytes tested is included(see attached Analytes For Baseline Sampling). Groundwater in the aforementioned wells shall be monitored for the water quality analytes listed in Tables 14 in the future,should there be a reasonable expectation that adverse groundwater quality impacts may occur. Reasons to monitor groundwater may include complaints,spills, releases, chemical use onsite. Furthermore, discharge water shall be analyzed regularly per the requirements in the CDPHE CDPS Discharge permit for the site. • Correct GW level data spreadsheet provided, and/or maps provided, so that the identification of the wells matches GW monitoring wells shown on the maps. A brief discussion of why the GW levels observed in several of the existing wells appear to have dropped dramatically since monitoring began would be helpful.. The identification on the Reclamation Plan Map has been updated to correspond with the GW level data spreadsheet. Groundwater levels in wells MON 1, MON 6 and to a lesser extend MON 2 have dropped since monitoring began in August of 2019. As shown on the attached graph,water levels in these wells began to drop in September of 2019 and have not recovered back to August 2019 levels. A drier than average local weather pattern(i.e.,drought)has been prevalent in the past two years and accounts for parched soils in the area, preventing recharge. Also, historical satellite images of the area show that around this time mining and dewatering began in the Varra Pit south of County Road 28 which could explain the drop in water levels in these wells. •Provide construction/survey information for all existing GW monitoring wells on-site, or at the very least, total depths, screened intervals, and elevations at GW level measuring locations. Construction/Survey information has been included for Monitoring Wells 1.8. Monitoring wells 9-12 will be removed after the provisional slurry wall leak test is complete and are therefore not included in the monitoring data. - Provide map showing locations of all eight permitted alluvial wells within 600'of the permit area as