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i • meet the requirements or the intent of Rule 3.1.7 (2) (a). The Division considers that establishing numeric permit conditions for ground water quality to be met at Points of Compliance will act to ensure the proper operation of the corresponding facilities that make up the proposed DMO which the applicant's current groundwater monitoring plan, without permit conditions, does not do. The applicant's "understanding" that the Division's objective is not to issue permits with conditions, which in this case aze considered necessary to the protection of groundwater quality and for meeting the requirements of Rule 3.1.7 (2) (a), is in error. It should also be noted that, contrary to the applicant's claim, the groundwater quality data supplied by the applicant do demonstrate that there are groundwater systems within the proposed DMO other than the spring-related system in Arequa Gulch and the Cazlton Tunnel. In fact, the applicant's adequacy response even contains a reference to the "Grassy Valley system". The applicant should propose numeric permit conditions in the application that aze protective of existing and reasonably potential future uses of useful ground water in and neaz the Amendment 7 azea. POINTS OF COMPLIANCE (CC&V response 31): The Division does not agree that Points of Compliance aze only necessary as a possible outcome of the on-going rule-making with the Water Quality Control Commission. The applicant is reminded that Rules 3.1.7 (2) (b) and 3.1.7 (6) specify that Points of Compliance shall be established not only to comply with groundwater standards set by the WQCC or to demonstrate compliance with permit conditions established by the Office but also to simply evaluate the protection afforded groundwater quality in a given azea. The applicant should propose Points of Compliance, as well as numeric permit conditions, for the DMO.