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I also do not agree that approval should be given for all future bore holes to be 12 inches. <br />While conducting research on 12 inch monitoring bore holes, I found mention of <br />monitoring well designs used by the EPA in California. Many questions arose after <br />reading this document: <br />1. Are these monitoring well holes or are they prospecting holes? There should be a stated <br />intention to drill monitoring well holes versus prospecting holes used for metallurgic <br />procedures. "When planning such surveys it is important to remember that drilling <br />methods and well casings /screens will influence the selection of geophysical methods (e.g., <br />electrical resistivity logging cannot be performed in cased wells). " http:// <br />www.dtsc. ca.gov /SiteCleanup/ upload /SMP_Monitoring_Well_Design.pdf <br />2. Why there is need for 12 inch diameter monitoring hole? <br />3. How much contaminated groundwater would be purged for testing? <br />4. Where the contaminated water be "stored ?" <br />Would not BLR's deep wells be purged of contaminated water from the Echo Park <br />formation (one of four area aquifers —see attached)? <br />Would that contaminated water (281 ug /1, 1979, Cyprus Mines Corporation, per Western <br />Water & Land 2009) be purged into a retention pond and "removed" as stated below <br />should be the case? (see attached Adrian Brown, P.E, Geohydrologist's description of <br />area aquifer properties) <br />Would the requirements for the new mud pits be the same as in the original NOI approval? <br />5. During hearings on HB 08 -1161 Geohydrologist, Robert Longenbaugh, testified that <br />there was danger of cross - contamination of downhole waters. Couldn't this happen more <br />easily while drilling a 12 inch diameter hole into a formation that will be hollowed out into a <br />cavern? <br />6. What downhole equipment would BLR need that necessitates a 12 inch prospecting bore <br />hole? <br />7. Below mention of purging of water from the holes also brings the question: How much <br />water will be used and does BRM have the water permits and water rights necessary for <br />these actions? These permits must be proffered to DRMS before this activity is condoned, <br />per rule 3.1.6 (a) compliance with applicable Colorado water laws and regulations <br />governing injury to existing water rights. <br />