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II. Ground Water Heading <br />Numerous portions of the permit application document concerning <br />ground water quality must be modified to reflect updated <br />information from monitoring. For instance: <br />a. The estimate of 2 percent salt loading increase from both mine <br />facilities (Exhibit 6, Page 1) may need to be corrected to <br />reflect more recent data gathered from stream sampling and <br />ground water monitoring. <br />2. Portions of the permit application document may also have to be <br />modified to reflect changes in ground water quantity, especially <br />mine discharge (Exhibit 6, Page 1). For example, the original <br />estimate of 180 gpm for the Golden Eagle (Maxwell) mine probably <br />has changed due to additional development work. Anew value based <br />on the additional area exposed should be developed. This applies <br />to the New Elk Mine as well. <br />3. Since some areas around the mine perimeter are being developed for <br />ranchettes and recreational home sites that would probably require <br />well water, it is important that the mine operators be aware of any <br />affect their operations might have on this ground water resource. <br />Since by definition, Colorado Law states that first priority water <br />rights (primacy) will be given to the highest and best use of that <br />water, which in this case is domestic use. Therefore, returning a <br />well such as LA-212 to monitoring status may be necessary to <br />monitor the bedrock aquifers. Presently no monitoring of bedrock <br />aquifers occurs except for springs and seeps. <br />4. Variations in bedrock (formational) permeability and storage may be <br />updated by including recent data acquired from the latest <br />exploration program in or near Apache Canyon and elsewhere. This <br />should be added to the current baseline data to enhance the <br />database. <br />a. If values change significantly it may then become necessary to <br />recompute mine inflows using the formulas found in the permit <br />application (McWhorter and Sunada). <br />5. The elimination of water quality test parameters for heavy metals <br />in 1984-85 is unjustified; especially, for Pb and Se since these <br />show up in relatively high concentrations in Wells LA-218A/221A, <br />PAW-2 (November 27, 1984) and mine discharge. Some of these <br />concentrations may be in excess of regulatory standards at times. <br />Additionally, fluorine increases at various monitoring points on <br />occasions. Therefore, it is probably necessary to retain at least <br />one monitoring point that tests for heavy metals and other <br />constituents (such as F) or some select heavy metals representative <br />of heavy metal suites. <br />6. To reiterate, maps and discussion of New Elk Mine indicate the <br />possible presence of a NNW trending linear element in the <br />