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Mr. Wallace H. Erickson <br />Response to August 23, 2011 Bird Memorandum <br />September 9, 2011 <br />Page 7 <br />Adequacy Issue No. E. Exhibit G - Water Information <br />1) Adequacy Issue #5.A. <br />a) The Applicant states that the point of compliance for groundwater will be <br />the monitoring well located on the May Day No. 2 bench, which appears <br />to be the closest accessible location down gradient of the active mine <br />operation May Day No. 1. Although this proposed location is not at the <br />farthest hydrologically downgradient extent of the permit area, it does <br />appear to provide the protections required under Rule 3.1.7(6). <br />b) For deep monitoring wells, describe the means by which water samples <br />will be extracted, i.e, type of pump, dedicated or portable, etc. <br />2) Adequacy Issue #5.C. <br />The Applicant must commit to providing, under Rule 6.4.21(8)(c), descriptions of all <br />geologic media down to and including the upper most aquifer under proposed sites of <br />material storage stockpiles waste piles disposal sites solution containment facilities and <br />other sites within the existing or proposed affected area where such subsurface materials <br />and any associated waters have the potential to be contaminated by designated chemicals <br />used in the extractive metallurgical process or by materials that are toxic or acid - <br />forming, or that produce acid mine drainage. Lacking detailed subsurface information as <br />does this site, the most effective means of collecting this information is by way of <br />detailed geologic logs of all drill holes completed on the property. The Applicant must <br />commit to completing detailed geologic logs and from those, detailed geologic maps and <br />cross - sections as well as structural contour maps of the permit area as well -log <br />information allows. <br />3) Adequacy Issue #8 <br />a) Per Rule 3.1.7 (7)(a), the locations at which down- gradient impacts may <br />reasonably be expected are not well known because the ground water <br />system is not adequately characterized. <br />b) Per Rule 6.4.21(8), the Applicant has not provided the general direction <br />and rate of flow of groundwater in the aquifers and fracture systems. The <br />information provided is primarily conceptual in nature or based on <br />surface observations. <br />c) Per Rule 6.4.21(9)(b) the Applicant has NOT submitted ground water <br />quality data collected during five successive calendar quarters. <br />DEN 97,591,783v2 9 -9 -11 <br />GREENBERG TRAURIG, LLP • ATTORNEYS AT LAW • WWW.GTLAW.COM <br />