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used in the model. The applicant's adequacy response refers back to the original groundwater <br />model using the 6 phases of mining and then also specifies the following criteria: <br />• The site shall be mined in 20-25 acre sections as depicted on the Mining Plan Map. <br />• 77te site will be mined and reclaimed concurrently. The mining shall restore the top of <br />the mining phase to reclamation condition as soon as mining is completed in a phase. <br />• The operator may not mine Pond 2 below groundwater until Pond 1 is reclaimed to <br />above the groundwater level. <br />• The applicant must begin constructing the slope liner after two phases have been <br />completely mined to bedrock by the miner. <br />Based on these criteria, the application does not adequately show and describe the major phases <br />of mining and the maximum disturbance to be expected at any one time throughout the life of the <br />mining operation in a manner that is clear and enforceable. Further, the assessment of <br />hydrologic impacts to the groundwater system within the affected land and surrounding area <br />does not coincide with a cleaz and enforceable mining and reclamation plan. Please revise the <br />mine plan, Mining Plan Maps, and assessment of impacts to groundwater resources in the <br />affected land and surrounding area based on maximum disturbance criteria that are clear and <br />enforceable. <br />For example, the applicant will need to clarify the maximum number of acres of pit excavation to <br />be expected at any one time throughout the operation and the de-watering requirements to <br />maintain such a dry pit excavation. The applicant will need to be specific in terms of specifying <br />the inputs used during the model simulation including volume and rate of pumping required, the <br />length of time of pit de-watering required for such disturbance until the clay liner construction is <br />completed, the linear footage of completed liner construction per cell(s) and expected <br />groundwater inflows for such azea, and the linear footage of unlined pit wall per cell(s) and <br />expected groundwater inflows for such area, and the acreage of unlined pit floor. If the applicant <br />elects to run the model both with and without mitigation measures to be employed, the applicant <br />should be specific in quantifying the mitigation measures to be employed. Following such <br />assessment, the applicant will need to describe the lateral and vertical extent of the predicted <br />groundwater impacts and the various offsite structures that will be affected, ie: high production <br />irrigation wells, shallow alluvial domestic wells, deep aquifer domestic wells, and wetlands <br />dependent on shallow alluvial groundwater. Please respond. <br />4. Pumping Rate - In conformance with Rule 6.4.4 and Rule 3.1.6(1), please describe the <br />maximum pumping rate necessary to completely de-water the maximum disturbed area as <br />specified above in Item 3. Also, please describe the length of pumping period(s) necessary to <br />maintain the maximum disturbance in a "dry condition", and the expected drawdown rate of the <br />groundwater surface at such a time. If the operator anticipates using multiple pumps during de- <br />watering and/or pumping from several of more cells during mining, please describe such <br />activities. Please respond. <br />5. The applicant has stated that wetlands offsite will not be adversely affected during pit de- <br />watering operations since they are supported only by surface water flows, and the expected <br />groundwater surface throughout the site is 20-25 feet below ground surface. However, the <br />wetland near the northwest portion of the proposed permit area is significantly lower in elevation <br />