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Objection to BMRI's AM-03 <br />Page 16 of 23 <br />February 22, 2008 <br />improve the ground water model and address the remaining <br />unresolved problems. (p. 128) <br />The Costilla Plain appears to be in the general area modeled by Mr. Lytle. Judge <br />Kuenhold's opinion noted that the Colorado Supreme Court has taken a critical look at <br />modeling and noted the criteria used in rejecting modeling results in which there is a <br />lack of acceptable modeling techniques. (p. 107) <br />While MODFLOW was utilized in the RGDDS study, MT3DMS does not appear <br />to have been utilized. The Report fails to define what is the nature and characteristics <br />of MT3DMS, its relevancy, accuracy, and background information describing it. <br />In addition, Mr. Lytle assumes that fluoride is the only constituent to reach the <br />ground water table at a concentration above background as a result of using West Pit <br />water irrigation. He apparently basis his assumption upon information from other <br />sources. <br />It is important that BMRI makes 'a showing that it has. adequately tested all <br />constituents of the waters in the West Pit'area, both as to historic background levels, <br />and current conditions, to be able to fully address the background levels of the <br />constituents in the West Pit water and the current levels of those same constituents in <br />the aquifer underlying the Salazar Ranch and the San Luis wells. Until this Is <br />accomplished, there is no comprehensive set of constituents for BMRI to base its <br />assumptions as to the affect of introducing waste waters into the aquifer. <br />In the Lytle Report, he uses MODFLOW and MT3DMS to focus upon the <br />predictive ground water and mass flow of fluoride toward the southern property <br />boundary well SLM-2. He submits a relatively simple overview of what he contends are <br />the dynamics of ground water flow in this area. He states that: <br />The model area, which includes the Salazar Ranch and the <br />town of San Luis (San Luis) is characterized by two layers, <br />with both of these layers having parameters that are <br />homogeneous and isotropic. The top layer is modeled as an <br />unconfined aquifer. The bottom layer is modeled as a