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• <br />vicinity of the proposed operation, precipitation flushing or gravel washing is not <br />likely to cause measurable increases in metals concentrations. <br />Radon. U~ and Plutonium. Radon and U'}' are part of the uranium decay <br />series and are found in very low levels in most rocks. Plutonium, practically <br />speaking, occurs only as a by-product of uranium enrichment. Plutonium probably <br />could not be measured in these rocks. <br />C. Concentrations of the above toxins and carcinogens will increase when t{~e alkrvial <br />gn•ounrdwater aquifer is disturbed. Lowering the tivater table will concentrate dissolved <br />solids. Mechanical cn~shing and washing will increase TDS and TSS. TDS will <br />increase at least 3 times over ambient concentrations. <br />RESPONSE. Disaggregation of unsaturated alluvium due to mining may increase <br />dissolved solids concentrations in the short term where previously unexposed salts <br />are exposed to water and then flushed out. Lowering the water table locally will <br />produce more unsaturated gravel and thus more water in the unsaturated zone for <br />evaporation. Mechanical crushing and washing will increase TDS to the extent the <br />newly exposed mineral surfaces are stored on site and allowed to weather. <br />Mechanical crushing and washing will increase TSS. <br />At nearby pits, TDS and TSS are monitored under the NPDES program, even <br />though standards are not developed for these parameters. Settling ponds are <br />established in the proposed mining plan to contain solids. <br />D. The operation qualifies as a DMO owing to potential adverse effects to gro:nndwater <br />or surface water. <br />RESPONSE. There is nothing about the composition of the aggregate that would <br />justify designating this operation for more rigorous monitoring or installation of <br />Environmental Protection Facilities (EPF's). Acid ortoxic-forming materials are <br />not part of the make of the gravel at this deposit. <br />E. The operation: tivill have tonic forming substances on site, some of which will be nnan- <br />rnade. No shndies regarding presence of acid or toxic forming s:~bstances. <br />RESPONSE. Naturally occumng materials, such as sulfide minerals, are not <br />present in the gravel in sufficient quantity to justify this objection or to justify <br />studies regarding the presence of acid ortoxic-forming substances. Mineralized <br />rock on site is rare. Man-made substances other than fuels and lubricants are not <br />proposed for storage or use on site. <br />