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Mr. Joe Dudash March 14, 1995 Page 3 11. The reference to discrepancies between water levels and transmissivity are moot since the wells referred to (Gl, G2, and UC & UL sequence wells) have either been replaced (UC-3, UC-1/LC-1) or abandoned. Results of on-going water level monitoring for wells HGl, HG2 and UC-2 are included in Annual Reclamation Reports. 12. Previous predictions of hypothetical contaminated groundwater movement are irrelevant since well monitoring data has indicated chat no groundwater con[amina[ion has occurred as a result of mining. Water quality data from semi- annual sampling of wells HGl and HG2 is included in Annual Reclamation Reports to the DMG. 13. Updated predictions regarding possible effects of springs and seeps on surface water quality were included as part of HGCC's November 1986 "Operator Response to Preliminary Adequacy Review". Subsequently, the Probable Hydrologic Consequences (PHC) was revised by [he CMLRD as part of the January 1987 Proposed Decision and Findings of Compliance (see pages 18 and 19). In accordance with previous discussions between HGCC representatives and the Division regarding the August 1994 Mid-Term review, it is our understanding that there is no need for further consideration of these issues and that previously submitted materials have satisfactorily addressed the hydrology-rela[ed questions. With regard to Parts II and III of [he Mid-Term Permit Review, HGCC provides the following responses. The "Consolidation" TR will include a list of all permi[ revisions and stipulations to Permit C-80-003 since the 1987 permit renewal (Part Il). Pazt III of the Division's review addressed reclamation performance bonding requirements. As we discussed, the "Consolidation" TR will also include a detailed estimate of the current outstanding reclamation liability and basis for reduction of the existing reclamation performance bond amount. HGCC will request that the Division approve bond reduction based on [hat estimate with the understanding that a separa[e bond release application may be needed. As noted during [he meeting, the ten year liability period will be comple[ed for all reclaimed areas in 1997. HGCC's present intention is to submit a Phase III bond release request in late 1997 with the goal of obtaining final bond release for all affected lands in 1998. The "Consolidation" application will be submitted in the form of a TR as the proposed revision will not constitute "a significant alteration of the terms or requirements of a permit" or "significant changes in the reclamation plan" (Rule 1.04(90), Definitions), which normally trigger the need for a Permit rather [han Technical Revision. It was agreed that if the Division needs more review time than the 60 days normally provided for review of a technical revision application, the Division can simply extend the TR review period. Since essentially no new information will be contained in the TR application, however, we hope that an extended review will not be necessary. el]/DUDASH.LTR 0]/14/95 4pm