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REV91571
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REV91571
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Entry Properties
Last modified
8/25/2016 3:13:05 AM
Creation date
11/21/2007 11:12:50 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1988112
IBM Index Class Name
Revision
Doc Date
4/30/1999
Doc Name
COSTILLA CNTY CONSERVANCY DISTRICT CCCD COMMENTS ON MARCH 1999 REPORT MLRB BY BMRI SAN LUIS PROJECT
From
KELLY/HAGLUND/GARNSEY & KAHN LLC
To
DMG
Type & Sequence
TR26
Media Type
D
Archive
No
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<br />Michael Long <br />Division of Minerals and Geology <br />Colorado Department of Natural Resources <br />April 30, 1999 <br />Page 2 <br />as Exhibit 4. After receiving protests by CCCD, BMRI agreed to drill an additional <br />monitoring well which complied with the Board's Order, but that action was not carried <br />out until sometime after February 25, 1999. <br />The Board required the drilling of this additional monitoring well aS a result of <br />testimony by Mr. Mefford at the January, 1999 hearing to the effect that a hvell in this <br />location would supply important data to enable the DMG and the MLRB to evaluate the <br />extent of the water quality problem and whether BMRI's proposed remedi¢I action <br />would adequately address that problem. See Exhibit 4. As Mr. Mefford nptes in his <br />comments at Exhibit 1, page 5, the BMRI's March 1999 report does not c¢ntain any data <br />from the well required by the Board Order, presumably because BMRI initially drilled <br />the well in a location which did not comply with the Board's order, and consumed much <br />of the limited available time in so doing. By the time BMRI drilled a second well in the <br />correct location, it was too late to collect the needed data in time for the March report. <br />Therefore, on behalf of CCCD, I request that the Board make no decision as to the <br />feasibility of BMRI's proposed action at this time. The monitoring informption from the <br />new well is every bit as important to an informed decision now as it was when the Board <br />ordered the monitoring well to be placed at the location recommended by Mr. Mefford. I <br />further request that the Board request BMRI to submit two months of monitoring data for <br />both new wells, SF-4 and SF-5, as soon as possible, and that the data, like the report, be <br />submitted to CCCD and other objectors, as well as to DMG, and that all oljectors be <br />given an opportunity to comment on that data before DMG makes a recommendation on <br />the report and before the Board makes a decision thereon. <br />Thank you for your consideration of these comments. Please contadt me if you <br />have any questions. <br />LP/sj m <br />Enclosures <br />r wo i.ooim~ve done aao-9a.pd <br />
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