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APR-20-2000 TNU 04:51 Ph <br />RMC <br />Ms. Lori Potter <br />April 20, 2000 <br />Page 4 <br />IDr3036656959 <br />FAX N~ <br />A 20'00 <br />12. SetYion 3, 1. page 11. first nar+tgra secynd sentence <br />P, 11 <br />16:33 No .010 P.05 <br />Inc <br />Bata for welt PC-2 or M-19 are not provided in 7R-028. Absent these data, it can not be concluded <br />that concentrations decrease by a fattor of three along this flowpath. <br />/3. Section 3~ 1. oars 11 reeond oar vranh <br />No analysis is provided to support the assumption that concenaatlons of sulfate in futons West Pit <br />groundwater wilt resemble groundwater currently produced by wel(BF-t. Without this analysis, this <br />assumption can not wpported. <br />14. Section 3, t, frLe- 1 Z fiLst (v/! bntencr <br />See Comment No, 5. <br />I5. Section I.A, Dare 13 <br />Sec our introductory remarks. We do not believe that sufficient data have been tollected to develop <br />an adequate postclosure ground"arer monitoring program for the West Pit. <br />T6. Section I 1 Hare T4 seeend lull parar-a_nh <br />A "dawngradient alluvial aquiler water management program" is discussed. This program should be <br />desvibed in detail, or the referenced letters should be provided in an appendix. <br />17. ,Section 4, 1, care 14. fourth full naraeraeh <br />Under TR-028, surface water station RS-5 Is not a point of compliance tPOC)- However, well M-34, <br />located approximately 2,000 feet downstream of the "window", is identified in TR-026 as the sole <br />POC for the Rito Seco alluviaUsurfacecaater system. Given the relative time of travel in the surface <br />water system versus the alluvial groundwater system, contamination emanating from the West Pit <br />could impart the Rito Seco surface water system for an extended period of time prior to it triggering <br />action at the M-3A POC. Because of the intimate connection between the Rito Seco alluvium and the <br />creek itself, the West Pit monitoring system must include a surface water POC, <br />18. Section 4.1. Q~e 1 S, continuing aararraolr <br />The Rilo Seco at the Shalom Ranch headgate should be included on the list of offsite monitoring <br />locations. On at least three occasions in the summer and fail of 1999 (August, September and <br />Novemberl, we noted that the concentration of manganese at the downstream Shalom Ranoh <br />Headgate exceeded that at the mine site boundary surface water monitoring location, RS-5. <br />