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conservative answer, the skeptics should be satisfied. If it does not, then the Division <br />might ask for more measurement to constrain the degee of sorption within this <br />stratigraphic column. As explained in the phone conversation [with Cotter Corporation] <br />it appeazs that the model does provide for sorption ofmulti-parameters, however the text <br />should better present input assumptions regazding the type and availability of the <br />absorbing materials. [Emphasis added.] <br />After more meetings with the Division, Cotter asked GeoScience to respond to the issues <br />raised by the staff. The report prepared on behalf of Cotter by GeoScience dated February 7, <br />2006 responds to the Division's January 17, 2006 letter review. After a detailed review of the <br />questions raised by the Division related to the PORFLOW Multiphase Transport Model, the <br />GeoScience report concludes in part, "The implications of this analysis suggest that <br />infiltrating water would actually dilute groundwater concentrations of species of concern. <br />Realistically, the impact from the waste rock piles on the underlying groundwater quality <br />would be `negligible'." <br />The GeoSciences' report also states, "The modeling simulations used in the Cotter Mine <br />reports used a zero value for sorption that is unrealistic but still results in contaminant migration <br />rates that failed to reach the water table." <br />Notably, the Februazy 7, 2006 GeoScience report concludes at page 5 that, "In summary, <br />modeling predictions using several conservative assumptions indicated that the waste piles from <br />uranium mining operations at the SM-18, JD-6, JD-8 and JD-9 mines pose minimal impact to the <br />environment." This GeoSciences' conclusion is based on the following factors: <br />1. Model predictions show that after 1,000 years of transport, no species of concem <br />reached the underlying water table; <br />2. Concentrations at the leading edge of the plume aze significantly lower than the <br />background concentrations in the underlying aquifers; <br />8 <br />