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l7. In conformance with Rule 3.1.6(1), please describe mitigation measures that will be <br />employed to minimize the permanent affects to the alluvial aquifer and surrounding area as <br />described in Item 15 above. <br />18. In conformance with Rule 6.4.7(3), please revise the estimate of project water requirements <br />to include the volume of water tied up in the pit run material, the volume of water needed for <br />washing operations, and the volume of make-up water needed for washing operations during the <br />mining phase of the operation; and the volume of water needed to fill the three (3) reservoirs to <br />maximum storage capacity during final reclamation. Please provide. <br />19. The applicant states on page 20 that they will apply for an NPDES Water Dischazge Permit <br />with the Water Quality Control Division prior to discharging water from the site. Please commit <br />to securing the approval of such permit from the Water Quality Control Division prior to any <br />water dischazge offsite, and providing written verification of such approval to the Division of <br />Minerals and Geology prior to any water dischazge offsite. <br />Groundwater Model -Lupton Lakes Proiect :Civil Resources LLC, February 2005 <br />20. The applicant states on page 6 of the report that the monthly groundwater data collected <br />indicates a slight hydraulic gradient of approximately 0.17 percent towazd the South Platte River <br />to the northwest. Please explain or clarify what is meant by a gradient of 0.17 percent towazd the <br />South Platte River. <br />21. Please characterize the seasonal fluctuations in the groundwater table in the affected land and <br />surrounding azea based on the affects snowmelt recharge, irrigation water users, domestic water <br />users, the South Platte River fluctuations, and any other significant inputs. Such chazacterization <br />should adequately describe the typical fluctuations currently experienced over the course of a full <br />12 months. <br />22. Please revise Figure 2a or provide an additional figure to show a typical cross section of the <br />Lupton I;akes Resource and surrounding area with the following features: South Platte River, <br />groundwater table after mining, existing ground topography, Fulton Lateral Ditch, existing water <br />table, estimated lake water surface, limits of mineable resource. (Attached is a copy of such <br />cross section provided for the M&G Pit, Permit M-1986-079). <br />23. The mining conditions specified on page 8 of the report and used during the model <br />simulation to predict the potential groundwater effects will need to be clarified and possibly re- <br />runbased on maximum disturbance criteria that aze clear and enforceable. For example, the <br />applicant will need to clarify the maximum number of acres of pit excavation to be expected at <br />any one time throughout the operation and the de-watering requirements to maintain such a dry <br />pit excavation. The applicant will need to be specific in terms of specifying the inputs used <br />during the model simulation including volume and rate of pumping required, the length of time <br />of pit de-watering required for such disturbance until the clay liner construction is completed, the <br />linear footage of completed liner construction per cell(s) and expected groundwater inflows for <br />such area, and the linear footage of unlined pit wall per cell(s) and expected groundwater inflows <br />