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the current situation presents an extremely low risk to human health as contaminant pathways may be incomplete or, at the least, are mixed ~vi[h dilution waters. Moreover, Mn and F at the measured concentrations are considered contaminants if ingested over long periods of time. However, we do not anticipate that the current levels will remain for the long term. Hydrokinetics, Inc. P. 32, ~ 3.2.2. DMG believes the operator is beins adequately conservative to collect multiple samples from the Santa Fe wells in order to characterize that formation. In that regard, the manganese analysis is not evidently "incorrect," as indicated by the reviewer. Rather, the number of samples is "not representative," as indicated by the operator. There is no indication that the wells have not been developed, but only that there are too few analyses, at this point, to offer a representative sampling of the Santa Fe Formation. Rocky Mountain Consultants 1. General Comment 1. The Division agrees to the extent that the entire database should be provided. 2. General comment 2. BMRI should address. 3. Page 18. The current hydrologic information seems sufficient to show that the mine pits are not hydrologically connected to the RS-3 station. Behavior of manganese between RS-3 and RS-2 should be evaluated. 4. Page 74, second bullet. Average pH values can indeed be computed from pH measurements by converting pH to concentrations before averaging and converting the average concentration back to pH. The operator's consultants have demonstrated proficiency at this task. 5. Appendix D, p. 18, Section 2.6?. Mule deer, not white-tailed deer, are present in the area. Both, if present, would be considered protected if agriculture standards applied to their water sources. 6. The surface water standards to be applied are those in effect for the Rito Seco. The Division recognizes exceedances of some standards at Station RS-2, and notes that RS-2 is upgradient of most mining disturbances as the Rito Seco dischazges to groundwater around that station. With regard to cyanide measurements, the Operator has been given the option on several occasions not to monitor for cyanide in the Rito Seco, as past cyanide leaching took place across a drainage divide from the Rito Seco and such monitoring seemed unnecessary. 7. The operator should address and correct any errors.