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Mr. J. David Holm <br />Water Quality Control Division <br />Page S <br />as asserted by the commenter. More importantly, to our knowledge, this unsupported <br />allegation is wholly inconsistent with the entire database cited above as well as at least <br />three subsequent on the ground inspections conducted by independent governmental <br />regulatory authorities in addition io the regulazly scheduled inspections by DMG in April <br />and June 2000. Given the overwhelming evidence in the record and on the ground, we <br />remain mystified as to why the commenters persist in such reckless and unfounded <br />assertions. <br />Containment and Manitorin>' <br />A number of commenters asserted that the contaminant plume, which resulted from the <br />West Pit has not been delineated, characterized, monitored or contained. These <br />assertions aze made without any supporting data and aze completely false, In fact, TR-26 <br />includes a comprehensive geohydrological chazacterization that included a delineation of <br />the azea of the downgradient Rito Seco alluvial aquifer that had been affected by the flow <br />of groundwater from the West Pit. In addition, TR-26 sets forth an extensive surface <br />water and groundwater monitoring program designed to confirm that characterization <br />over the course of the initial response activities. Again, contrary to the assertions of the <br />commenters, the geohydrological characterization and monitoring program is extensive, <br />consisting of over twenty-eight wells and monitoring points and has been in place for <br />over 18 months. The results of the TR-26 geohydrologic chazacterization and the <br />monitoring program have been used to corm the expected horizontal and vertical <br />extent of the "plume" of elevated TDS and sulfate levels which resides in the alluvial <br />aquifer (See TR-26, Figures 3-8 through 3-1 I), predict the potential for movement of <br />contaminants through the alluvium and develop and implement adown-gradient <br />monitoring and containment program which will ensure that any residual alluvial waters <br />affected by the West Pit are captured and returned to the pit for treatment and <br />dischazge.(See TR-26, Sec. 6.0). This system is fully operational and is functioning as <br />planned. These facts aze a matter of record in the TR-26 approval and your files <br />supporting this draft permit. As noted previously, in accordance with an order of the <br />