2022-02-23_PERMIT FILE - M2021059 (13)

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To: `1r. Peter HayN Date: Februat-v 21, 2022 PaLlre 26 Response 4 We are glad to discuss this comment with the reviewer as we are unclear about the comment's reference to two feet. The text from Section 5.3.1 in Appendix D from the October 2021 response to application completeness states: "Figure 16 summarizes the anticipated changes in groundwater levels associated with neighboring wells. Nelson shows approximately two feet of drawdown well within a range that will not negatively change their ability to withdraw irrigation water from the well. The two Wagner wells will likely experience around afoot of mounding, affecting their wells in a positive manner. The largest potential impact shown is to the Dunn well, where it approaches the 10%of well depth criteria. Drawdown is only one component of a well's ability to extract water. The lakes in Cell 2 and Cell 3 will effectively enhance the production of the well by developing a constant groundwater level nearer to the well. Thus,for the same amount of pumping, the required drawdown in the well will be much less and the well will operate more efficiently." The paragraph identifies the Dunn well as one that requires monitoring. LRM is working with the owner to establish baseline and a monitoring approach as the project commences. Comment 5 In Figure 16 three of the four wells graphed have a starting point that indicates increased water levels, shouldn't all wells begin at 0.0 indicating no mining influence? Response 5 Figure 16 starts at the end of Step 01 (mining of the first five acres). All drawdowns prior to this are zero. Comment 6 All groundwater sample results need to be compared to the Water Quality Control Commission's (WQCC) Regulation No. 41 — The Basic Standards for Groundwater (Reg 41) and the most conservative values in Tables 1 thru 4 for all analytes listed for minimum offive consecutive quarters. The sample results from the June/August 2021 sampling event only compared results to WQCC Reg 41 Tables 1 and 2. Table 3 of Reg 41 are agriculture standards which contain a few analytes that Tables 1 and 2 omit. Response 6 We have added comparisons to WQCC Regulation 41 Table 3 to the initial water quality testing results, and have updated the footer(Attachment 15). 20220209 1045_DBMS_Adequacy Review Response_MASTE Rdoex TELESTG