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Mr. Carl B. Mount July 21, 2003 Page 6 of 10 (1) Standards and conditions applicable to classified and unclassified groundwater. (a) State-wide groundwater quality standards: Operations that may affect groundwater quality shall comply with all state-wide groundwater quality standards established by the Water Quality Control Commission (hereafter, the WQCC-. (41 Procedures for establishing compliance with standards promulgated by the WQCC. (el Permits, or applications to modify a permit shall not be approved unless such permit or modification includes conditions adequate to implement ail groundwater quality standards promulgated by the WQCC applicable to such permit or modification. 16) Points of Compliance: (a) In order to evaluate protection afforded groundwater quality, comply with groundwater standards, or to demonstrate compliance with permit conditions established by the Office to protect groundwater quality, one or more points of compliance shall be established. This application fails to identify appropriate and adequate procedures for establishing compliance with WQCC standards. In fact, this application fails to address background water quality, applicable ground water quality standards or methods proposed to comply with applicable WQCC standards. Additionally, it appears that the application has failed to establish one or more points of coii~piiance as more specifically required by Rule 3. i.7. Pursuant to Rule 3.1 .7(4-, this permit application may not be approved until these deficiencies are adequately remedied. For numerous reasons, including but not limited to, the predictable but unplanned-for groundwater exposure, the counterproductive posture of the applicant in submitting a profoundly flawed, inaccurate and misleading application, and the size, type and intensity of proposed industrial uses that are proposed to complement the mining uses on the property, this proposed mining operation must be preceded by an effective groundwater baseline/monitoring program as described and required by Rule 3.1.7(7-.