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<br />Specific Comments, WAI Responses, Apri15, 1995; Page 4 <br />The Ph,ise 1 area of this permit is the most critical link in the hydrologic system as it now exists. <br />Hydrographs for the wells downgradient of this area were provided to you in CDPHE's original <br />comments on this permit application. They were provided to Steve Boand of AQUASAN who <br />was providing hydrologic advice to AGRA Earth and Environmental and were included in the <br />report Fie provided to WAI. They are not included in this response document. An employee of <br />AGRA requested the hydrographs from CDPHE after this document was delivered for review. <br />The hydrographs for RFETS wells 55-86, B400189, and B400389 show yearly Fluctuations of 5 <br />to 10 feet and high water levels range between ]0 and 20 feet below ground surface. The <br />proposed depth of mining within 100 feet of these wells is 30 feet below present ground surface. <br />Rerouting the Smart Ditch around the area to be mined may lower these water levels somewhat <br />but the larger and permanent recharge source, the Smart reservoir, will remain in place. <br />Page 13 point 9 indicates that WAI intends to break ground on this project by May 1, 1995. A <br />ground breaking date of May 1, 1995 is premature. The Phase 2 area is much less sensitive <br />although it also requires monitoring to ensure the ground water table is not encroached. The <br />Phase 1 area needs to have the Smart ditch diversion in place and at least 6 piezometers in place <br />to monitor ground water levels for a year before the ground is disturbed. The Phase 2 area needs <br />at least 3 piezometers and Phases 3 and 4 need, at least, one each. Piezometers are a low cost <br />investment compazed to the anticipated profit on this project. <br />There is a suggestion on page 13 of the Western Ecosystems report that surface flows into <br />drainages below the mining areas be enhanced. Since plutonium may be present in the Woman <br />Creek sediments this suggestion needs careful study. <br />There may be other professional opinions about the possibility of re-establishing and maintaining a <br />warm season grassland in the reclaimed pits. The shallow depths to ground water and potential <br />seasonal flooding, if mining proceeds according to this plan, are considerations in analysis of <br />hydroio€;ic and ecologic data. 7~he mining plan including the reclamation portion will 'nave to <br />reflect th.e requirements of the conservation plan for RFETS. <br />