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Annetta Qr:iil <br />1)avc nkcr> <br />Junc12,2000 <br />Page ~ <br />Rita J~co :~ranstrcam of tltc Wcst Pit which arc potentially the result of ~round`a•atcr <br />discharges cram the Nest Pit to flee ltito Scco. <br />15. Tributary wafers <br />The scttlcttt.nt properly recognizes That waters of the seep arc tributary to the Ritu Scco. <br />1 he setllem~nt fails to reoognite that because of impacts associated with excavation of <br />the pit au<f ;ira hydraulics of the aquifers present, waters of Iha Precambrian, Santa Pc <br />and alluvial aquifers, as well as the West Ptt, arc all tributrry to the Rito Scco. The <br />setUemcn[ :ails to properly consider the impacts of pollutants found in the Wcst 'it to the <br />Rita Soco. <br />l6. Conclusions of I,atir <br />"l'Ite cortclus~olts of law in the scttlerncnt do not address tributary groundwater di~chargcs <br />associated with seepage from the West Pit. <br />17. Penally Assessment <br />'I'Ire scttlcmcnt states that tlrrcc components were cousidered to initially assess the <br />penalty: fruit, potential damage, and economic benefit. We address these bcloa. <br />The penalty asscssrnc:t[ ()Ottlon of the scttlerncnt relics on 13M's Ecolobrical Risk <br />asscssincrrt without critiquing its zrdcgtracy or the appropriateness of ifs data. It fails to <br />include:rrty per)alty associated with flee economic benefits of HM's non-compliartca 1t <br />detennincs that tlrcre have hccn no downstream impacts to classified uses without <br />considering data from srny locations downstream of RM's propetry. The settlement fails <br />to consider potential downstream groundwater impacts such as flee extensive corrosion to <br />rm irrigation well located on the Shalom Ranch immediately downstream of the l3M <br />propcny. <br />We requested the documents trnderlyirtg the calculation of penalties, and received the <br />April 21, 2000, n)crt)o by Caria Lerrkey to Darcy O'Connor, EPA, and the April; 2000 <br />document by WQCD entitled "Rattle Mountain Gold Cconomic Acncfit Analysis." <br />I V101 MI W.ntlV eyL. mull r.rlan~ yM <br />