2008-03-03_REVISION - M1988112

• Permit No: M1988112
• IBM Index Class Name: REVISION
• Doc Date: 3/3/2008
• Doc Name: Public Comments
• From: INFORM
• To: DRMS
• Type & Sequence: AM3
• Media Type: D
• Archive: No

Colorado state-wide. Additionally, "all "Agricultural Use -Quality"
ground waters must meet these standards when implemented by any
agency," including DRMS (CDPHE, Regulation 41, page 33). Thus, as
detailed herein, it appears that ground water quality standards may not be
met by this operation.
o Should BMRI choose to petition CDPHE to change Site-specific
radioactive materials and organic pollutant standards on site in regards to
proposed agricultural water uses, BMRI must comply with CDPHE
requirements to do so (Regulation 41).
^ 1. In determining whether to adopt site-specific standards to apply
in lieu of the statewide standards established in subsection C
above, the Commission shall first determine the appropriate
ground water classifications within a specified area, in
accordance with section 41.4.
^ 2. The Commission shall then determine whether numerical
standards other than some or all of the statewide standards
established in subsection C above would be more appropriate for
protection of the classified uses, taking into account the factors
prescribed in section 25-8-204(4), C.R.S. and section 41.4. The
downgrading factors described in Regulation No. 31, section
6(2)(B) of the Basic Standards and Methodologies for Surface
Water shall not apply to the establishment of site-specific
standards under this subsection.
• Fluoride concentrations, aslisted in Table 3-1, Ground Water Quality Results for
Samples Collected on July 2, 2004, and measured by San Luis West Pit Ground
Water Well BF-SR, of 3.2 mg/L exceed the Colorado Water Quality Control
Commission agricultural standard (CDPHE, Regulation 41) for Fluoride of 2.0
mg/L.
• Man€;anese concentrations, aslisted in Table 3-1, Ground Water Quality Results
for Samples Collected on July 2, 2004, and measured by San Luis West Pit
Ground Water Well BF-SR, of 2.37 mg/L exceed the Colorado Water Quality
Conb~ol Commission agricultural standard (CDPHE, Regulation 41) for
Manganese of .2 mg/L.
• "Cun•ent copper concentrations vary with location in the west pit" (Appendix A,
page 9). "Current copper concentrations measured in ground water monitoring
wells on the western portion of the West Pit are higher than the shallow pre-
minirig concentrations from We1187-86" (Appendix A, page 9).
Human Healtl'z:
The proximity of the West Pit and the proposed ground water disbursal is within 2 miles
of the Town of San Luis.
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