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J <br />' • • <br />applicant's claims, groundwater quality is not well known for the entire district and the limited <br />data supplied do not adequately chazacterize baseline groundwater quality conditions for all azeas <br />of the proposed operation. There are significant gaps in the groundwater quality data supplied for <br />the Gold Run area which renders rather questionable the applicant's assurance of having more <br />than 12 quarters of baseline data available for that azea by the time the adjacent valley leach <br />facility begins to operate. There has been no groundwater quality data supplied from the <br />monitoring wells the applicant has in SW Section 16, NW and SW Section 17 and SE Section 18 <br />which not only lie within the proposed expanded permit azea but also neaz enough to elements of <br />the proposed operation that the groundwater they monitor may be impacted by the operation. <br />The applicant should supply additional groundwater quality data for the Gold Run area, <br />ie. the immediate area of the proposed expanded heap leach, in order to meet or more closely <br />approach meeting the requirements of Rule 6.4.20 (9) (b). The applicant should also supply any <br />groundwater quality data in his possession for the SW Section 16, NW and SW Section 17 and <br />SE Section 18 or provide a clear statement that no ground water was encountered by these wells. <br />GROUNDWATER MONITORING PLAN (CC&V responses 25 and 29): The <br />Division does not agree with the applicant's claim that there is no potential for groundwater <br />impacts by the proposed operation and that the Environmental Protection Plan requirements of <br />Rule 6.4.20 (12) aze being met by the limited monitoring plan proposed. To begin with, it is the <br />Division's opinion that the currently proposed monitoring plan does not provide for adequate <br />monitoring of the potential impacts of the ADR on useful groundwater in the Bateman Creek <br />drainage. Groundwater quality records demonstrate that WCMW-2 is already contaminated by <br />cyanide and that WCMW-9 is consistently dry. In addition WCMW-1, being southwest along the <br />drainage divide adjacent to Bateman Creek instead of south of the ADR and towazd Bateman <br />Creek, is poorly located for monitoring the potential impacts of the ADR on the Bateman Creek <br />drainage. By the omission of the applicant's known monitoring wells in the SW Section 16, NW <br />and SW Section 17 and SE Section 18 from the monitoring plan, the applicant is ignoring the <br />need to adequately monitor the potential impacts of the operation, ie. by pits, old pads, <br />overburden dumps and shop, on groundwater in those azeas of the DMO. In addition, the <br />application does not commit the applicant to monitoring of the discharges of the various tunnels <br />which the proposed operation is admitted to have some potential to adversely impact. <br />The water monitoring plan described in the application and illustrated on Fig. 5 should be <br />revised to include the tunnels, wells WCMW-5 and WCMW-3 together with the applicant's <br />known monitoring wells in the SW Section 16, SW and NW Section 17 and SE Section 18 in <br />order to demonstrate the proper operation of the DMO's facilities nearby as well as to adequately <br />comply with the requirements of Rules 6.4.20 (12) and 3.1.7 (7). If no groundwater has been <br />encountered by the monitoring wells in SW Section 16, SW and NW Section 17 and SE Section <br />18, a cleaz statement to that effect will suffice to justify excluding these wells from the <br />monitoring plan. <br />PERMIT CONDITIONS (CC&V response 30): The Division is awaze that the <br />applicant's commitments in design and monitoring will provide some protection to groundwater <br />quality in certain azeas of the proposed DMO but does not agree that these commitments entirely <br />