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APR-20-2000 THU 04:49 PI1 FAY. H0~ P, 06 <br />Water quality protections in the Mined Land Act and'vILRB Rules are not limiWd to <br />chemical pollution or acid mine drainage caused by chemical reactions in mined materials, Any <br />worsening of water quality due to "disturbances in the lrydrologic balance" must be "minimized" <br />by all pcrmitlecl operations. CRS 34-32-1 lG(7)(g). <br />In this case, I3MRI admits that the excavation of the West Pit and the resulting hacklill <br />fists rentovcd the ori~rinal hydrologic condition that allegedly prevented ground water froth the <br />pre-Catnhrian bedrock from llowiug to the Rito Seco - the green clay fault zone. Thus, the <br />company is msponsible for any resulting chanbe in the hydrology and water quality. <br />Any argument by the company that ground water compliance levels, or surface water <br />quality levels for that matter, should he relaxed to account for the now co-mingled aquifers <br />ignores the basic duties placed on operators by the Mined Land Act and Rules. In this case, the <br />fact that rite unaffected deep Precatttbrian wells show very high levels of contaminants is cattsc <br />for alarm -- not cause to conclude that the 0.05 mg/I. manganese standard will be met. <br />Conclusion <br />1~K-2g represents a potential lung-lenn picture of the San Luis Minc site. Based on our <br />review, this picture is very troubling. The lack of any real assurance as to how fire site will meet <br />all watec quality conecrr~ in both the short and long temt is becoming more and rnorc <br />problematic for local residents. Moving compliance points away from rite achra] source of <br />polluliott is trot the solution. In addition, attempting to circumvent full public review via yet <br />another technical revision fundantuitally undermines 13MK1's proposals and DMG duties to the <br />public. <br />Thank yon For the opportunity to submit these preliminary comments. We rnorc that the <br />reason we ntttst yttalify these comments as "preliminary" is that we and our cottsultitnts have not <br />received sufficient ttoticc of TR-28 or adcgttatc time to cotttmcnt, as we would have i f this TK <br />had been treated as a pcnnit amendment. We also note that EPA has not been asked to review <br />this TR notwithstanding its impacts oft wafer quality issues which LPA is reviewing. For this <br />reason as well, DMG should treat TR-28 as a permit atuendmcnt and establish a full public <br />notice attd comtncnt period. Finally, we note that Jitn Dillie has assured us that these <br />preliminary comments will be considered by DMG i f transmitted to DMG by today, April 20, <br />2000. <br />