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SFfvT BY~ XEROX Te!ecapier~l7: 6-13-a4 ~ 9.51AM : <br />~~ <br />408652-+ 39a B32 8106~if 3 <br />-f - <br />This monitoring will hopefully confirm that stream standards for the Rito Seco <br />and ground water.table values for domestic use are met. Stream standards are required <br />to be met since the company admits that ground water infiltration from the pit will <br />likely reach the Rico Seto (G-4). Ground water protective values should be based an <br />the Board's recently adopted ground water rules to protect existing and rrasanably <br />potential future uses, such as domestic use in the errs. Thus, on a parameter-by- <br />parameter basis, the morestringent of either the surface or ground watex values should <br />be made conditions of the permit. <br />We do not, however,.feel that these additional protective measures should delay <br />the implementation of the baclcfilling. Thus, PASS proposes that the Board/Division <br />conditionally approve this amendment on the express condiflon that additional <br />monitoring requirements are implemented as soon as possible. At a minimum, this <br />monitoring will enable the Division to ascertain baseline conditions as called for in the <br />Board's new Designated Mining Opetadoa rules: <br />Overall, these limited monitoring requirements, like the backfilling, should be a <br />win-win situafion for all involved. For the Division and the public which i t represents, <br />timely monitoring results will alert the state to the need for any change in operations of <br />corrective action if things do not go a, planned. For the company, mina~r up-front <br />costs will be more than made up far in reduced clean-up costs in the event problems <br />develop. While it is tempting to trust the company's predictions that nothing will go <br />wmng, monitoring is a low-cost (compared Wclean-up) way to ensure that the <br />predictions of success are hopefully realized. <br />Thank you for the opportunity to voice our concerns. We would be happy to <br />discuss these issues with the Division. and the company at your convenience, especially <br />since a conditional amendment approval should not delay the' ssart of bacldilting. <br />S' y, <br />R .Flynn <br />Director <br />ATTORNEY FOR THE PEOPLES' <br />ALTERNATIVE ENERaY SERVIC~PS <br />cc: Bruce. Humphries (DMt3) <br />Dean Massey (BMG) <br />Nora Jacquez. (CCCD) <br />Maria Moadragon-Valdez lPAE4) <br />