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Dan Hernandez <br />June 3, 2013 <br />Page 2 <br />have compiled and reviewed relevant data from the PAP, Findings, Division of Water Resources <br />database, AHRs, and other related hydrology reports. The results of my review are summarized <br />in the following sections and include a discussion of applicable groundwater regulations, <br />hydrogeology of the site, groundwater monitoring, surface water concerns, and conclusions and <br />recommendations. <br />Appropriate and Applicable Groundwater Quality Reaulations <br />Under the Senate Bill 181 (SB 18 1) amendments to the Colorado Water Quality Control Act <br />(CWQCA) classification of State Waters is the sole responsibility of the Water Quality Control <br />Commission (WQCC). For unclassified groundwater areas, the applicable and relevant <br />standards are the Interim Narrative Standards (INS) from Regulation 41 (41.5(C)(6)), that <br />addresses all groundwater for which standards have not already been assigned by the WQCC, <br />with the exception of those areas where total dissolved solids (TDS) equal or exceed l 0,000mg/l. <br />Under the INS the standards that would be in effect at the Southfield Mine (site- specific <br />groundwater classifications and standards have not been applied at this location) are the least <br />restrictive of either: <br />1) existing ambient quality as of January 31, 1994; or <br />2) the most stringent criteria from Table 1 through 4. <br />There is a provision in 41.5(C)(6)(b)(iii) to allow for the use of water quality data collected after <br />January 31, 1994 when it can be reasonably demonstrated that there has been no site activity <br />since that time that would contribute to the further groundwater quality degradation. With this <br />provision data generated subsequent to January 31, 1994, shall be presumed to be representative <br />of existing quality as of January 31, 1994, if the available information indicates that there have <br />been no new or increased sources of groundwater contamination initiated in the area in question <br />subsequent to that date. Thus the standard for compliance should be either the ambient water <br />quality (if applicable) or the most stringent criteria from Tables 1 through 4. Tables 1 & 2 are <br />Domestic Water Supply - Human Health and Drinking Water Standards, respectively, Table 3 <br />are Agricultural Standards, and Table 4 are TDS Water Quality Standards. Regulation No. 41 <br />"The Basic Standards for Ground Water" were adopted in January, 1987 and became effective <br />March 2, 1987. <br />The provision in 41.5(C)(6)(b)(iii) essentially allowed for some level of groundwater quality <br />degradation up to a certain point in time while Regulation 41 was coming into effect and being <br />implemented. Since mining by the current operator Energy Fuels Coal, Inc. occurred both before <br />and continued after the January 31, 1994 date, the use of ambient water quality as representative <br />of existing quality does not apply to this area in question. So the table value standards set forth <br />in Tables 1 through 4 of "The Basic Standards for Ground Water" would apply to the Southfield <br />Mine site area. Under the CWQCA, State Waters are broadly defined and include all <br />groundwater regardless of aquifer yield or production rates. <br />In order to effect compliance with ground water standards, one or more points of compliance <br />shall be established. In Regulation 41 the Division of Reclamation, Mining and Safety along <br />with other state agencies are referred to as "implementing agencies ". Implementing agencies <br />