2008-03-03_REVISION - M1988112 (21)

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I Objection to BMRI's AM-03 Page 20 of 23 February 22, 2008 secondary drinking water standards as well as primary drinking water standards. If not, waste waters should never be imported to an area that. impacts drinking water standards. The real issue is not, as BMRI contends, the current level of water quality In the West Pit area. BMW's report needs to address these important criteria as they are at the heart of its land dispersal concept. MISCELLANEOUS Historically, the two quarter sections on the Shalom Ranch have grown grain crops in the past without using waste waters. There is no reason to believe that there was not a sufficient supply of waters to historically sustain crop production on the two quarter-sections of the ranch. Under AM-03, waste waters supplied to these quarter- sections are being used on crops merely to find an altemate means to deal with untreated waters at the mine site, as opposed for use to sustain .a crop. The crops can be sustained upon the current source of supply with needing "waste waters" for irrigation. BMRI seeks to create a "waste water" right of some type. An existing school is located in close proximity to the Shalom Ranch. In addition, the Town of San Luis is located almost adjacent to the Shalom Ranch. The Shalom Ranch is located in close proximity to persons that live in and around the area, and rely upon ground water to supply their domestic needs. The Town of San Luis and its inhabitants throughout the area also use domestic wells from an aquifer shared by the Shalom Ranch. There has been no showing in AM-03 that the general health and safety considerations of the immediate community have been addressed. The land dispersal concept necessarily connotes that constituents, including TDS. and manganese, from the untreated waters will be introduced into the farm ground soil. Natural precipitation and/or irrigation waters from the sprinkler system presumably will, over time, move some of those constituents and deposits through the soil layers into the underlying aquifer. The permit amendment application indicates that current conditions of ground water chemistry in the West Pit are of a water quality that is consistent with pre-mining