2023-02-24_PERMIT FILE - M2022013 (3)

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We also recognize an oversight in prior responses regarding the basis for Mr. Peter Christensen being a qualified person. The relevant statute and regulations as we understand them do not define a qualified person but require that maps "must be prepared and signed by a registered land surveyor, professiona[ engineer, or other qualified person". Mr. Christensen is a qualified person by virtue of education, training, and experience. He holds a degree in Mining Engineering awarded by the University of Queensland (Australia) in 1985. During his subsequent 37 years in the mining industry, he has attained various statutory or professional designations including Registered Member of SME, New Mexico Mine Foreman, MSHA Underground and Surface Instructor, and Queensland (Australia) Site Senior Executive. He has attended short courses on environmental compliance and the NEPA process. His experience specific to permit preparation, permit review, and operating in conformance to permits includes preparation of state and federal permits in West Virginia, Wyoming, New Mexico, and Colorado, as well as foreign jurisdictions both state (or equivalent) and federal in Canada, Colombia, Indonesia and Australia. Review or audit of compliance with permit operating conditions has been undertaken in many more states and foreign jurisdictions. He has held responsibility for ensuring operational permit compliance and completing mining or exploration activity reclamation in West Virginia, Wyoming, and New Mexico, and has presented on the subject at conferences and educational workshops. Additional items were included in the Third Adequacy Review and have been addressed as follows: A groundwater monitoring plan, prepared by AWES, was submitted with the January 4, 2023 packet. The plan proposes to use 12 existing holes, which were completed as 1" monitoring wells in 2015. Boring logs are given as an appendix to the plan, but no well completion data is available.The elevation of each hole is given in a table in Exhibit G, Addendum 10, together with monthly water level data from September 2015 through June 2022. Adequacy comments on the proposed plan are given below, organized by the section of the plan itself. Section 1 of the proposed plan states the objectives and gives the background information. Item 16. Section 2.2 states that water levels will continue to be monitored on a monthly basis during dewatering operations, then quarterly for one year following reclamation, then annually unti I the permit is terminated. Item 16. Please amend section 2.2 of the plan to continue quarterly monitoring until the permit is terminated We have amended the Groundwater Monitoring plan (updated as a new addendum) as requested. Section 2.3 describes the monitoring of groundwater quality. It states that "two baseline samples will be obtained from one upgradient and two downgradient wells no less than two