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CIVIL RESOURCES <br /> quality of water in surface and groundwater systems both during and after the mining operation and during reclamation <br /> shall be minimized. <br /> The Division is requiring groundwater quality monitoring throughout the life of mine to <br /> demonstrate compliance with Rule 3.1.6 during active mining. <br /> The Division requests the Operator commit to providing the quarterly groundwater monitoring <br /> results along with the monthly level measurements by the following deadlines: <br /> •First quarter report due by May 1st of every year. <br /> • Second quarter report due by August 1st of every year. <br /> • Third quarter report due by November 1st of every year. <br /> •Fourth quarter report due by February 1st of the following year. <br /> At the end of five quarters, MMMA may submit a Technical Revision to reduce the analyte list <br /> and frequency of monitoring with sufficient justification. Analytical sampling frequency will not be <br /> reduced to less than a minimum of twice yearly(high flow and low flow data with a collection <br /> interval of 5-7 months). <br /> • As discussed in the meeting between the Division and MMMA on May 15, 2024, Section 5 of the report <br /> has been updated to include the conditions below. <br /> MMMA will commit to performing 5 quarters of baseline monitoring at PZ-01, PZ-04, PZ-09 and PZ-20. <br /> After the baseline period has ended, MMMA will move to twice yearly monitoring of the four listed <br /> monitoring wells. The twice yearly monitoring will be performed during March (Low Flow) and <br /> September (High Flow) of each year. MMMA will report these results according to the following <br /> timetable: <br /> o March sampling report due by May 1st of every year. <br /> o September sampling report due by November 1st of ever year. <br /> Within 60 days of completion of the baseline sampling period MMMA will submit a Technical Revision <br /> to the Division containing a report with the baseline period data and an analysis of the data. The <br /> baseline period for wells PZ-04, PZ-09, and PZ-20 will end the 1st quarter of 2025. Since PZ-01 was not <br /> identified as a water quality well until the 2nd quarter of 2024, PZ-01 will require one additional quarterly <br /> sampling performed in the 2nd quarter of 2025. 60 days after the 2nd quarter sampling of PZ-01 MMMA <br /> will submit the Technical Revision to the Division. <br /> 3. In response to item 12, MMMA provided the full list of analytes (Appendix B) for the monitoring <br /> wells. The analyte list is inconsistent with the Appendix A of the Division's Groundwater <br /> Monitoring: "Sampling and Analysis Plan Guidance Construction Materials and Hard Rock Sites" <br /> (September 2023). Appendix A of that guidance document has been provided for your reference <br /> and inclusion into your Groundwater Monitoring and Analysis Plan. Appendix B, as provided, <br /> includes sampling for more analytes than needed. <br /> 9 Appendix B has been updated to represent the analytes shown in the guidance document. <br />