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will require a commitment to a trigger point once the current conditions are assessed for potential groundwater impacts at <br />the site. The Applicant's second adequacy review response redefines the trigger point as "a 2-ft. drop." As indicated in <br />the previous adequacy review letter, the Division must withhold approval of a set trigger point until a model <br />incorporating current conditions at the site can be reviewed. <br />6. The second adequacy review letter requested detailed information regarding mitigation measures that will be <br />incorporated in the event that groundwater is impacted in the vicinity of the site. The Applicant has indicated that if <br />groundwater is impacted, the following will occur, "cessaton of mining and/or dewatering operations, which will allow <br />the pit to refill to pre-mining levels and goundwater levels to rebound. We propose that the cause of groundwater level <br />drop be de[em~ined by an independent, third-party water specialist, agreed upon by all parties." Although the Division is <br />in agreement with the assignment of a third-party groundwater specialist to the investigation to submit suggestions as to <br />the cause of groundwater impacts, the Division retains the right to determine the cause of impacts. Additionally the <br />Division is not in agreement with the assumption that cessation of mining and/or dewatering operations will allow <br />groundwater levels to rebound. If the presence of the slurry wall is the cause of groundwater level impacts, cessation of <br />dewatering and allowing the pit to refill may not affect the impacts produced by the slurry wall. <br />7. The second adequacy review letter indicates that the Division requires a specific mitigation plan to be in place prior to <br />approval of the permit application. The mitigation plan submitted as part of the second WWE report merely suggests <br />possible measures that may be incorporated in the event of groundwater impacts but does not commit to a specific <br />mitigation plan. Additionally, the submitted plan focuses solely on the Coyle and the Aquafic and Wetland Nursery <br />(AWC) properties. Please commit to a specific mitigation plan and specify how impacts to parties other than the Coyles <br />and AWC will be mitigated. <br />8. The second adequacy review response indicates, with regazd to mitigation measures, "the Applicant is working directly <br />with interested parties to reach an agreement that serves all parties involved. If reached, this agreement could supersede <br />the measures outlined above." Please be awaze that any changes to the mitigation plan need to be submitted to Ute <br />Division in the form of a Technical Revision or Amendment to the permit. <br />9. The second adequacy review requested that the Applicant specify in their groundwater monitoring plan, the location of <br />monitoring wells and the number and location of private wells to be incorporated in the plan, the frequency of <br />measurement, and the reporting pazameters. <br />a) The second WWE report specifies the locations of wells to be used for monitoring and of proposed <br />pie2ometers to be installed. The plan does not reflect any monitoring locations upgradient of the slurry <br />wall to measure potential mounding. Please include at least one upgradient location in the monitoring plan. <br />b) The second WWE report indicates that groundwater level monitoring will occur monthly "for a minimum <br />of one year prior to mining to enable determination of baseline conditions." For clarification, the Applicant <br />has agreed to the one year of baseline water level measurement prior to installation of the slurry wall. Also, <br />please indicate the frequency of water level measurement following the fast year of activity at the site. <br />c) Please commit to submitting the water level data to the Division for review within 30 days of measurement <br />each time data is collected. <br />Rule 6.4.8 Exhibit H- Wildlife Information <br />10. In the second adequacy review response, the Applicant requested, "the current plan be approved as proposed with the <br />condition that the U.S. Fish and Wildlife Service's opinion be submitted to the Division for review prior to <br />commencement of operations. If Fish and Wildlife's opinion creates a need for change in Mining and Reclamation <br />Plans, the Applicant will submit a Technical Revision or Amendment." The Division is considering whether a <br />stipulation to this effect can tie incorporated into the permit and will have a decision regarding this issue on August 4, <br />2003, at which time the Applicant will be advised of the outcome. <br />Rule 6.5 Geotechnical Stability Exhibit <br />11. The Geotechnical stability review is neazly complete. The results of the review will require some minor adjustments to <br />some of the proposed setbacks for the site. The results will be forwarded to you as soon as they aze complete. <br />