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Update to Wildlife Resources Assessment, Cemex C-Pit and CKD Disposal Site <br />Page 3 of 7 <br />shorebirds. There is no aquatic food chain present in the remaining pond in C-Pit. Fish are <br />absent, as is aquatic vegetation (Figure 31)). Aquatic invertebrates are either insignificant in <br />numbers or absent. Current selenium levels at the pond are not toxic to waterfowl and shorebirds <br />that make contact with the water, or ingest the water. Therefore, it is not realistically possible for <br />the occasional aquatic waterfowl to bioaccumulate toxic levels of selenium at this pond. In <br />addition, there are no attractive mudflats for shorebirds given the steep sides of the pond. <br />Findings and Recommendations <br />The 2004 report found that that the probability of adverse impacts to wildlife from water in C-Pit <br />was low to very low under the conditions present in 2004. This situation is much improved since <br />that time. At this time, the probability of significant adverse impacts to wildlife from water in C- <br />Pit is very low. <br />The 2004 report also recommended against use of a net over the water that would obstruct avian <br />access to the water. Cemex has tried to use nets anyway, but the nets typically have been <br />shredded by high winds and require constant maintenance. Again, I recommend against the use <br />of nets. There is no significant, quantifiable danger to wildlife if they come into contact with this <br />water now that the pH is lower, and selenium levels are non toxic. In fact, at this point, I believe <br />the net, and net shreds blowing in the wind or floating on the pond, represent a significantly <br />larger hazard to wildlife than the water itself. <br />In addition, since that water is now non toxic, I see no advantage in Cemex maintaining daily <br />wildlife observation logs. Four years worth of logs are in hand, and they show that even the <br />much larger pond was little used by wildlife. The current pond is less of an attraction or hazard to <br />wildlife. I would rather have Cemex put its limited funds and staff time into the following: <br />1. Reduce the current pond to about half its size, around one-quarter acre of surface area, if <br />possible, while retaining the high banks and steep slopes. This will make the pond even <br />more unattractive to waterfowl and shorebirds. <br />2. Continue to implement the plan to use the pond for a water supply for the cooling tower at <br />the plant, including mixing with water from A-Pit. <br />3. Retain the cables and red streamers over the pond, in lieu of netting (Figure 31)). These will <br />provide discouragement for birds to land in the pond, and require far less maintenance than <br />netting, and be less hazardous to wildlife. <br />4. Continue the program of reduction of available ground water in the area around the pit. This <br />includes lining more of the Boulder Feeder Canal west of the pit, and completion of the <br />filling of the Brick Pond. <br />An adequate water quality monitoring program is already in place. <br />If you have further needs on this issue, please contact me. <br />Sincerely, <br /> <br />Michael G. Figgs, President <br />LREP, Inc.