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Loretta Van Norstrand Page 2 of 3 <br />July 4, 2001 <br />boundaries for which flux is calculated for a given boundary head (mixed head and flux <br />condition). <br />That is the technical answer to your question. I realize the subject is complex and difficult for you to <br />understand. In fact, the subject was too difficult for the individual writing the Camilleti response <br />letter. I assume it was their attorney because they got totally lost in the technical jazgon they were <br />using to justify no injury to Milner wells. In their response to Concern 3 (page 3) they are using the <br />term boundary conditions but it is apparent they have absolutely no understanding of what physical <br />boundary conditions mean or as they use the term hydrologic boundary conditions. Their convoluted <br />statement (Camilleti's) that Trout Creek and the Yampa River will dictate the water table in the <br />alluvium absolutely misses the point. Hydraulic boundaries can be used to calibrate a steady state <br />mathematical flo~.v model (a flow condition that doesn't change with time) but it is not acceptable for <br />modeling a transient condition (flow quantities or water levels that change with time) nor is it <br />acceptable for steady state predictive simulations (what if scenarios where pumping would be <br />included at some point). The reason for this is the model assumes that conditions on the boundaries <br />never change from the initial values. Under transient conditions heads (water levels) change due to <br />applied stresses (i.e., dewater pumping, exposure ofthe alluvium through trenching and excavation). <br />Hence their (Camilleti's) assumption that water levels in the future (predictive mode) are entirely <br />dependent on water levels in the two rivers is absolutely wrong! <br />Having given you this brief explanation of boundary conditions I seriously doubt there was ever a <br />groundwater model developed to evaluate the effects that dewatering will have on the Milner wells. <br />I think technical jargon is being used to brush over the concerns raised, and is presented instead as <br />a substitute for performing an actual evaluation of the effects on groundwater flow. <br />The 2nd issue and the one I have reviewed in detail is the floodplain study. It appears from the <br />questions raised by DMG they have not done a detailed review of the Camilleti study performed by <br />Water Resource Consultants, LLC, nor have they read my response letter report. The theme that runs <br />throughout the Camilletti response letter, evident by response to Concern 3 (page 3) and in many <br />other sections of the letter is the 100-year flood elevation never leaves the banks of either Trout <br />Creek or the Yampa. Hence it is legitimate for them to mine anywhere on the property. The idea that <br />the 100-year flood is contained inside the river channels is the main point of contention that I raised <br />in my response letter report. We asked for but was never provided with a satisfactory survey map and <br />field survey cross sections. In addition, they selected the wrong gage for Trout Creek, they made a <br />false assumption that a Swale located on the property would intercept and drain flood flows away <br />from the property, and lastly I questioned the accuracy ofthe cross sections they used to model flood <br />stage elevations in their HEC-RAS setup files. <br />