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<br />under 3.1.7(3)(b) of the Rules it provides for <br />procedures for requiring modification of an <br />existing operation permit to address the blaming <br />of the actual or reasonable potential for adverse <br />affects to beneficial uses of groundwater. <br />The State(ment) of Basis that was issued, in <br />relationship to Section 3.1.7, we believe <br />recognizing that existing, as well as new or <br />amended permits, may be affected by the new <br />groundwater protection requirements. However, it <br />is our view that it provides that the requirements <br />are applicable to activities of operations in a <br />perspective and not a retroactive fashion, that <br />is, not reaching back through time. So, our view, <br />with the Bulldog site...ceased the operations in <br />1985, and we shutdown after mining activities <br />there. And the reclamation activities were <br />essentially completed by the latter part of last <br />year...with the exceptions of what I noted <br />previously. The State(ment) of Basis also states <br />that the existing groundwater conditions should be <br />acknowledged and requirements should not be <br />imposed that would require remediation of <br />substances already in groundwater. Groundwater <br />quality at the Bulldog is already contaminated by <br />natural mineralization. We know that from past <br />mining activities and what we have for water <br />9 <br />