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Division of Reclamation, Mining and Safety (DRMS) to make certain that closing the <br />operating water treatment plant, and/or utilizing West Pit ground water for irrigation, will <br />have no advert>e effect upon Colorado's citizens and environment; and will meet all <br />applicable ground water quality standards as enforced by the Colorado Water Quality <br />Control Commission. For this reason, INFORM incorporates the points and objections <br />raised in those letters to the extent they have not been fully addressed. <br />Groundwater: <br />Appendix A, "Analysis ofpre-mining groundwater quality in the vicinity of the west pit" <br />as intended to provide a comparison ofpre-mining and post-mining groundwater <br />conditions, falls short in providing an adequate comparative analysis for several reasons. <br />Table 2 of Appendix A identifies "vertical trends in water chemistry with increasing <br />concentrations closer to the ground water table (i.e., shallower depths) and lower <br />concentrations deeper in the aquifer" (Appendix A, page 4). The reasoning behind this <br />statement is attributed to "natural fluctuations in the ground water table enhanced the <br />oxidation of sulfide in the upper portions of the saturated bedrock aquifer, with <br />decreasing effi~cts of oxidation at depth due to limited oxygen content" (Appendix A, <br />page 4). <br />As an initial concern, utilizing We1187-86, a shallow mineralized bedrock aquifer, as a <br />representative pre-mining sample when weighing aquifer contamination as a whole, is not <br />adequate. We feel that ground water conditions of the west pit azea should be compazed <br />to each pre-mining well, as measured cumulatively, without identifying We1187-86 as the <br />primary means of comparison. In addition, please consider and respond to the following <br />list of concerns: <br />• CDPHE Ground Water standards: <br />o In regards to ground water chemistry at the West Pit, two constituents <br />exceed Colorado state-wide applicable ground water standazds. DRMS <br />must work cooperatively with the Colorado Water Quality Control <br />Commission (WQCC) under the Colorado Department of Public Health <br />and Environment (CDPHE) to ensure ground water will meet agricultural <br />standards. The intent of the Colorado Water Quality Control <br />Commission is to protect ground water quality from uncontrolled <br />degradation and thereby protect existing and future uses of ground water <br />(CDPHE, Regulation 41, page 25). "Agricultural Uses" are the existing <br />or potential future uses of ground water for the cultivation of soil, the <br />production of crops, and/or the raising of livestock (CDPHE, Regulation <br />41, page 4). Even if ground water chemistry is indeed found to be <br />consistent with pre-mining conditions, ground water utilized to support <br />crop irrigation at Salazar Ranch must meet CDPHE agricultural ground <br />water standards. Despite site specific attributes and conditions at the <br />Salazar Ranch which may allegedly naturally mitigate the effects of <br />increased manganese concentrations by means of absorption and <br />oxidation, CDPHE ground water standards are applicable across <br />2 <br />