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successful, the BMP's should terminate flow through the window during active <br />pumping. Quantification of flows through the window should assist in assessing <br />the degree of success achieved by the BMP's doting active remediation, and will <br />assist in evaluating the system in the passive treatment period until contamination <br />is no longer a problem. <br />Response: <br />The tiered-discharge approach for Dischazge Point 001 provides the flexibility <br />necessary to reasonably represent the probable range of flows that aze expected to <br />occur during the extraction of groundwater from the West Pit. For the purposes <br />of the CDPS permit, BMRI will pump the backfilled West Pit as necessary, up to <br />a maximum flow rate of 400 gpm (30 day average), to maintain a state of reversed <br />hydraulic gradient. <br />The alleged flow of water at the seeps reported by Mr. McGowan has not been <br />substantiated. The historic seep azea has been visited by the DMG, CDPHE, and <br />the EPA (NPDES, Emergency Response) since February 8, 2000 and all of the <br />inspectors have affirmed that the seeps no longer flow. In addition, water levels <br />recorded for groundwater in the backfilled West Pit demonstrate that the <br />hydraulic gradient between the backfilled West Pit and the Rito Seco alluvial <br />aquifer has been reversed according to the TR-026 water management plan. <br />Thus, the groundwater flow from the West Pit to the Rito Seco alluvial aquifer <br />cannot occur and the surface water and groundwater flow associated with <br />Dischazge Point 002 has been eliminated by the implementation of the TR-026 <br />water management plan. BMRI commits to maintaining the reversed hydraulic <br />gradient in the West Pit throughout the period of the CDPS permit. <br />An estimate of the current groundwater flow rate from the backfilled West Pit is <br />not necessary at this time because the hydraulic gradient has been reversed and <br />groundwater is now flowing into the backfilled West Pit. The response of the <br />groundwater system in the vicinity of the West Pit, as recorded by the <br />performance monitoring program, has occurred in a manner that is consistent with <br />the representation of the system developed in TR-026. <br />Ba!(le ,4/ounmin Resources, /nc. HS/ GeoTrans <br />14 ~nlY zl, zooa <br />