2023-12-18_PERMIT FILE - P2023018 (2)

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through the Division of Water Resources, as well as all construction information required under Rule 5.4.4. There is no known hydrological documentation in this area that would help indicate which exploration holes may be converted to groundwater monitoring wells at this time. It is not possible to begin the permitting process with the state engineer's office until the specific drill holes identified for conversion are selected,as stated in the NOI. It was our understanding that the Rules and Regulations allow conversion of a exploration drill hole to a monitoring well in accordance with sections 5.4.3 and 5.4.4. If this is not allowed,we will withdraw the request to convert any of the drill holes into a monitor well under this NOI. If during drilling, a suitable monitoring well location is found, it could be submitted for approval at a later date as a modification to the NOI as described in section 5.1.1 (3),or as a separate NOI. Section 4: Operation and Reclamation Measures 6. Item 4 of Section 4 details multiple P&A methods based on various groundwater conditions. For all holes to be drilled, including those that will be converted to monitoring wells,provide supporting hydrologic documentation to clarify which P&A method is to be utilized at which hole to minimize impacts to the prevailing hydrologic balance pursuant to Rule 3.1.6(1). If the hydrologic information, including depth to Groundwater is unknown or unavailable, the Division will be required to default to cement plugging to depth for each hole. The abandonment procedures were described in the NOI to reflect the unknown and variable conditions that may be encountered at each drill site,and which plugging and abandonment method would be employed based on the encountered drill hole conditions. This was intended to demonstrate our understanding and acknowledgement of the Permanent Abandonment of Prospecting Drill Holes guidance in section 5.4.2 of the Rules and Regulations. If the Division wishes to prescribe a single P&A methodology for the entire project,we request that a high quality sodium bentonite type gel,specifically developed for use as an abandonment fluid,be utilized. Artesian flow of groundwater is not expected in any of the drill holes,which is the only groundwater scenario calling for neat cement grout in the Rules and Regulations. If artesian flow of groundwater is encountered,neat cement grout will be used pursuant to section 5.4.2 of the Rules and Regulations. 7. Item 5 of Section 4 calls for the use of excavated spoils and drill cuttings to achieve reclamation grade, however drill cuttings may contain ore body materials and should be handled accordingly. Please commit to on site disposal of all cuttings with a minimum of 36"of total cover over the disposal location at each pad. The operator commits to dispose of all drill cuttings a minimum of 36"below grade within the mud/sump pit at each drill site. No mineralized material will be left within 36"of the final surface. 4