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Objection to BMRI's AM-03 <br />Page 18 of 23 <br />February 22, 2008 <br />ranch will remain in a "safe area"? Is it appropriate to define the safe area as that area <br />of the aquifer underneath the ranch? What legal principle guides Mr. Lytle in making <br />that contention? <br />What is meant by the contention that: <br />Continued irrigation of the Salazar Ranch irrigation pits with <br />West Pit water will not adversely affect any current or <br />reasonable foreseeable future use of ground water between <br />the pivots and the SLM-2 well (Since BMRI controls use <br />throughout this reach.) <br />What does the term "continued irrigation" mean? <br />Mr. Lytle contends that the process used for this evaluation was to develop a <br />conceptual model of ground water flow, including aquifer parameters and boundary <br />conditions, which provide a representative simulation of ground water flow conditions <br />beneath the Salazar Ranch. Either two or three observation points, (it is not dear as to <br />the exact number in addition to SLM-2.) are used to monitor the fluoride mass moving <br />through the ground water. Is this a sufficient means to monitor the fluoride levels in the <br />aquifer? Is this enough monitoring points based upon the apparent rate and direction of <br />the ground water flow toward the town of San Luis? <br />Moreover, what safeguards are In place to insure that the monltoring is sufficient <br />for the intended purpose? If the intended purpose is to make sure there is no <br />detrimental impact on the town wells, domestic wells in the vicinity, stock wells and <br />other irrigation wells, how is that result assured? <br />How does one assure that there is not an unforeseen problem with the untreated <br />waters reaching other wells? If excessive levels of fluoride are found in the target area <br />- the area beneath the ranch - what procedures are in place to remedy the problem <br />before it leaves the targeted area? Are wells in place to Intercept the waste water? If <br />the unwanted waste water is intercepted, is it then pumped back to the West Pit area for <br />treatment? Does the water treatment plant need to be in place for immediate activation <br />if necessary?