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Objection to BMRI's AM-03 <br />Page 12 of 23 <br />February 22, 2008 <br />mg/I. at SLM-2 which will not adversely- affect any current or reasonabiv foreseeable <br />future use of around water, given that aroiected around water fluoride concentrations is <br />well below any beneficial use standards. <br />As an overview, the analysis is flawed for several important reasons: <br />1) BMRI assumes that a plan that decreases the quality of ground water is <br />acceptable in principle as part of the land dispersal concept. However, the application <br />does not focus upon what persons, or communities, or water interests may be impacted <br />by the degradation, and the potential detrimental nature of the impact. It fails to <br />address how fluoride, or manganese (if it ultimately reaches the ground water table), <br />could negatively impact persons consuming the. water. Likewise, it fails to address the <br />consumption of these constituents by domestic animals. Why not look at applicable <br />drinking water standards, as Us clear that the town of San Luis uses its wells for <br />municipal purposes? <br />2) What "beneficial use standards" are purportedly applicable for these <br />purposes? The term "beneficial use" usually refers to the right to pump appropriated <br />waters during the irrigation season to grow a crop. Here, although the suggestion is to <br />the pontrary, irrigation of crop lands is an incidental part of the land dispersal <br />considerations. The primary purpose of the plan is disposal of waste water.. The <br />beneficial use term leaves open many questions. <br />3) The report further assumes that fluoride is the only constituent in the West <br />Pit water that is "predicted to reach the local ground water table at a concentration <br />above background as a result of using West Pit water for irrigation...." (p. 1) The <br />report estimates that 15% of the applied water is return flow to the local ground water <br />table. (Lytle Report, p.5) As the ground water flows downgradient, this fluoride then <br />disburses and the resultants concentrations decrease. (p.7) As a result of run of the <br />ground water model, the total increase in fluoride concentration at steady state is <br />predicted to be approximately .92 milligrams per liter (mg/L.)