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Grand River Park Project, M-2006-046 Response to Adequacy Letter of August 1, 2006 6 September 2006 Page 14 concerning injury to well users, as administered by the Office of the State Engineer and the Division of Water Resources (as referenced in item 19 above). It is the intent of the applicant to preserve the viability of all permitted wells in the area. While marginal differences in pumping rates are to be expected with the addition of a gravel well, more pronounced effects on shallow wells, if experienced as a result of the gravel well, may prompt the operator to provide assistance with pumping equipment, furnish imported water, or other mitigation actions for the duration of such a substantial impact on well viability. As a purely quantitative issue pertaining to water rights, the TSSP and gravel well permit provide the proper process to determine when the threshold for injury to groundwater rights will occur. Construction Materials Rules do not provide sufficient guidance to determine appropriate triggers for well user mitigation measures. Minimally, the applicant will investigate complaints asserting with some reasonable degree of probability that the mining operation is affecting well viability. To establish baseline groundwater levels, as noted on page 19 of the Exhibit G and mapped on Exhibit C-1, the applicant has installed three groundwater monitoring wells on the site. These groundwater monitoring wells are located at strategic points to provide data on the influence of mining and dewatering on the surrounding groundwater hydrology. Results will be forwarded to the Division prior to the commencement of operations and periodically thereafter. 22. In accordance with Rule 6.4.7(2)(c), please submit a statement or plan showing how water from de-watering operations or from runoff from disturbed areas, piled material and operating surfaces will be managed to protect against pollution of either surface or ground water both during and after the operation. Standard water management practices incorporated into the design of the Grand River Park Project will protect against pollution of both surface and groundwater at the site. A key feature of the site is the stormwater detention and clarification basin to be built at the northeast corner of the site. This basin will intercept all surface water and all dewatering water prior to discharge off-site to the Colorado River. stormwater runoff from all points of disturbance on the site, including piled material and operating surfaces, will be directed to the stormwater basin. The basin will be designed to provide detention capacity for at least a 25-year storm, with additional capacity to accommodate clarification of pumped water at