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shows that fractures behave as capillary barriers that restrict the movement of water in the <br />unsatm•ated zmre. Direct evidence of this unsaturated zone process is provided by the mine <br />itself that intersects the fault but shows no evidence of water movement along the fault. <br />We can properly use the same rationale as that identified above for the 7D-6 <br />Mine for estimating groundwater levels underlying the mine's waste pile. Using the alluvial well <br />in the Paradox valley, the elevation of JD-8 is 6470 Feet and located approximately 3 miles from <br />the alluvial well in the Paradox valley. Using a similar hydraulic gradient and the elevation of <br />the mine, groundwater levels wtderlying the site may exceed a thousand feet. <br />The Cotter migration pathway computer analysis.shows that constituents of <br />concern reach only 400 feet in depth at concentrations of one millionth of initial concentrations <br />after 1,000 years. The net result is that the plume at the defined concentrations fails to <br />reach the groundwater -even after 1,000 years. A monitoring well would have to be drilled <br />hundreds of feet beyond the extent of any potential plume and would provide little useful <br />information regarding potential environmental impacts. <br />E. Computer Mode[ine Results Support Cotter's Request for Exemption. <br />The computer model submitted by Cotter's consultant, Peter Kearl of GeoScience <br />Services ("GeoScience"), adequately demonstrates the lack of impacts from Cotter's operations. <br />Indeed, there is precedent for the Division to allow use of computer modeling which <br />demonstrates, among other things, that dilution of contaminants with fresh water or ground water <br />will result in compliance with ground water numeric protection levels. if dilution is selected as a <br />means of meeting groundwater numeric protection levels, the operator is allowed to construct or <br />use a computer model showing that dilution rates can be expected if rain or snow melts drives <br />pollutants from the rock piles into local ground water. <br />7 <br />