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For the JD-8 mine, the sole basis for the Division's determn~ation relates to Cotter's submission stating that the faults are non-transmissive. The Division appears to suggest that a monitoring well and detailed bore logs axe needed at the JD-8 mine, as well. D. There is No Need For Deeu Monitoring Wells at the JD-6 or JD-8 Mines Cotter submits, however, that there is no need to drill monitoring wells and develop extensive boring logs at either the JD-6 or the JD-8 mines because other substantial geologic information has been presented to the Division that demonstrates that Cotter operations will not adversely impact groundwater at Those sites. For instance, Cotter submitted to the Division Supplemental Geology Reports for each of the JD-6 and JD-8 mines in July 2006. These reports included a report prepared by GeoScience Services concerning the role of fractures in unsaturated- transport. This information and analysis explains the rationale for the conclusion that additional information and data is not needed and is summarized here. See Attachment D, hereto. JD-6 Mitae The Division has expressed concern that groundwater in the alluvium is hydraulically cotmected to the bedrock resulting in a shallower groundwater surface beneath the JD-6 mine's waste pile. The attached generalized cross-sections includecross-sections for each of the JD-6, JD-8, JD-9, and SM-18 mines. For the JD-6 and JD-8 mines, the cross-sections show the relationship of the upper most aquifer (Eutrada Sandstone) to the alluvimn in the Paradox Valley. The well which is present in the Paradox Valley alluvium is located approximately 3200 feet from the JD-b mine's waste pile and has a depth to water from land surface of 260 feet. Since the Division's concern assumes that groundwater flows from the alluvium and recharges the bedrock, the hydraulic gradient would yield a higher groundwater level at the well 5