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shown elevated concentrations of species of concern, Cotter's transport modeling has shown that <br />the species of concern would reach the upper-most aquifer at concentrations which are one <br />millionth of the initial concentration-even using the ultra-conservative (and totally mrrealistic) <br />assumption that zero sorption occurs. <br />There is not an analytical Instrument available that can measure these low <br />concentrations. In addition, the Division's analysis does not consider the dilution effects of <br />relatively large fluxes of groundwater mixing with extremely low fluxes of infiltrating water <br />containing the species of concern. <br />Thus, even with groundwater infiltrating the JD-9 mine, there are no realistic <br />impacts to the environment ar human health. <br />E. Computer Modeling Results Support Cotter's Request fa- 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 gowtd water. <br />hi the normal course, the Division carefully evaluates the proximity of ore'and waste rock <br />piles to surface and ground water resources. This analysis is typically based on site-specific <br />examinations that consider the proximity to streams, u~d ground water, as well as the size of ore <br />6 <br />