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20. Please provide a reclamation plan for the four monitoring wells located on site. Please include the <br />depth of wells, diameter of the wells and how the wells were completed. This will assist the Division <br />in determining a final cost of reclamation. <br />21. The groundwater model prepared by the applicant did not take account of the dewatering and dry <br />mining of the 10-acre Phase 1 pit that will not be lined with a slurry wall. The pit will ultimately be <br />backfilled to approximate original contours, but with overburden and shale extracted from Phases 2 <br />and 3. Please revise the model to include the dewatering, mining and reclamation of the Phase 1 pit. <br />22. Please depict the location on a map where mine water will be dischazged. If mine water is dischazged <br />into a ditch or other man-made structure, please provide consent to discharge water into this structure. <br />If water is dischazged into a ditch that is unlined, it may be prone to erosion if the discharge rates <br />exceed the carrying capacity of the ditch. The applicant should submit documentation to the Division <br />for review as to the proposed maximum discharge rate into the ditch and specifications as to how <br />much water the ditch can carry without experiencing erosion. <br />23. The groundwater report does not specify the maximum drawdown of wells in the surrounding area as <br />a result of the slurry wall or the 10-acre pit that will not be lined. Please address this issue <br />accordingly. <br />24. The Division received comments from the Office of the State Engineer (OSE) regazding the proposed <br />application. According to the OSE, before a well permit can be approved the applicant must conduct <br />a field location of the site and document the locations of all wells within 600 feet of the permit area. <br />The applicant must then obtain a waiver of objection from all well owners with wells within 600 feet <br />of the permit azea or request a hearing before the State Engineer. See the attached OSE letter for <br />further detail. Please commit to not exposing groundwater until a well permit is obtained from the <br />OSE. In addition, once the well permit is obtained a copy must be submitted to the Division. <br />25. A more detailed review of the groundwater model will be forthcoming, and additional questions may <br />arise based on the review. <br />Rule 6.4.10 Exhibit H-Wildlife Information <br />26. The applicant suggests that mining in the southwestern portion of the site commence once the <br />burrowing owls have left for the winter. Please state the dates in which the area will be avoided and <br />mining will not occur in this area. <br />Rule 6.4.10 Exhibit J- Veeetation Information <br />27. Wetlands aze noted to exist on site (noted as A, B and C). Please state if the areas defined as wetlands <br />will be reclaimed to wetland areas and provide additional information regarding the reclamation of <br />the wetlands. In particular, please state the final reclaimed slopes, depth of topsoil to be replaced and <br />the wetland seed mixture to be utilized. <br />Rule 6.4.12 Exhibit L- Reclamation Costs <br />28. The operator is requesting that 20% of the slurry wall liner be submitted, with the commitment that <br />the slurry wall will not be constructed until construction information is submitted. For an operator to <br />be eligible for the 20% bonding option, the Division must have a high degree of assurance that the <br />liner or slurry wall installed by the Operator will meet the State Engineer's performance standard. <br />This assurance is provided through inclusion of design documents, plans and specifications, and a <br />quality assurance program as enforceable components of the reclamation permit. The factors that <br />must be addressed in the reclamation plan include the design of the slurry wall (including <br />construction plans and appropriate drawings), technical specifications, construction quality <br />controUconstruction quality assurance (CQA) and a final construction report including the CQA <br />