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<br />Objection to BMRI's AM-03 <br />Page 19 of 23 <br />February 22, 2008 <br />What. if elevated levels of fluoride are detected in the town wells? What if the <br />levels exceed drinking-water standards? What if other constituents are found in the <br />town wells that ultimately relate back to the waste waters in the West Pit area that were <br />not tested for prior to commencement of the land dispersal process? <br />Mr. Lytle concludes that: "Since the input of fluoride mass to the ground water <br />system was constant over time, fluoride concentrations reached steady-state conditions, <br />i.e., the concentrations over time didn't change once they were at steady-state." (p.6) <br />What areas is he addressing? Are we dealing with the aquifer area beneath the ranch <br />itself, or the aquifer as a whole? Does this area include the town wells? . Does this <br />area include other domestic wells in and around the area? What underlying data, <br />documents and studies. does Mr. Lytle rely upon? Are all of the relevant inputs to the <br />model described in the report? Has the report been tested by peer review? <br />If one reaches "steady-state" concentrations, does that actually. assume an <br />impossible situation? Based upon the assumption that there is a constant rate of <br />infusion of fluoride during the irrigation season on an annual basis at the two Salazar <br />ranch wells, should one not presume that there will be a build-up over steady-state <br />concentrations at some point of time at some portion of the aquifer? What Is the rate of <br />dispersal of the fluoride after-it reaches the ground water? How is it calculated? Will <br />constant injection of fluoride into the aquifer mean that increased concentrations of it <br />must be dealt with somewhere in the aquifer based upon a pure. physical principle? <br />Can one be assured that the increased concentrations of fluoride do not occur outside <br />the area of the aquifer beneath the ranch? <br />Does Mr. Lytle qualify as an expert modeler in computer modeling? What is the <br />nature of his expertise? What is his level of experience in using MODFLOW in <br />conjunction with MT3DMS? <br />This is a critically important scenario in taking West Pit untreated waters and <br />discharging them directly into the aquifer for consumption by the town people for <br />drinking water purposes. The real issue is whether the West Pit waters currently meet