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Dreyer, James I., 1988. The Geochemistry of Natural Waters, 2 edition, Prentice Hall, Inc.,
<br />Englewood Cliffs, NJ, 437 pp.
<br />Langmuir, D. & Riese, A. C. 1985. The thermodynamic properties of radium. Geochimica et
<br />cosmochimica acta 49, 1593 -1601.
<br />Schott, B. & Wiegand, J. 2003. Processes of radionuclide enrichment in sediments and
<br />groundwaters of Mont Vully (Canton Fribourg, Switzerland). Eclogae Geologicae
<br />Helvetiae 96, pp. 99 -107.
<br />Smith, Brice, and Amonette, Alexandra, 2006. The Environmental Transport of Radium and
<br />Plutonium: A Review, Institute for Energy and Environmental Research, June 23, 2006.
<br />Szabo, Z. & Zapecza, O. 1991. Geologic and geochemical factors controlling uranium, radium -
<br />226, and radon -222 in ground water, Newark Basin, New Jersey. US Geological Survey
<br />Bulletin 1971, p. 243 -265.
<br />Zwahlen, Francois, Surbeck, Heinz, and Gainon, Francois, 2007. Natural radionuclides in
<br />groundwater as pollutants and as useful tracers, Swiss Centre for Hydrogeology,
<br />University of Neuchatel, Switzerland, published in Proceedings of the 12th International
<br />Symposium on Water -Rock Interaction, Kunming, China, 31 July - 5 August 2007,
<br />Yanxin Wang and Thomas D . Bullen , ed.
<br />Page 5, Item 11(B)
<br />Section 15(a)(iii), page 15 -3. The EPP discusses a possible detailed human health risk
<br />assessment to determine potential pathways for human exposure and possible alternative
<br />concentration limits. So long as the AFA is in direct hydraulic communication with Ralston
<br />Creek, which is a drinking water source, the Operator must take measures designed not only to
<br />reduce the concentrations of contaminants in the AFA to meet the state ground water domestic
<br />water supply standard, but more importantly, to ensure that Ralston Creek meets the drinking
<br />water quality criteria defined by the state WQCC. DRMS will not accept any alternative water
<br />quality criteria.
<br />Ralston Creek itself is not a drinking water source, although it feeds into Ralston Reservoir.
<br />Ralston Creek contributes a small proportion of flow to the Ralston Reservoir. The reservoir is
<br />primarily filled with water from a transmountain diversion tunnel and is one of several sources of
<br />drinking water for the city of Denver and its western suburban areas. The uranium stream
<br />standard applicable to Ralston Creek is the standard that applies. The groundwater point of
<br />compliance is at SW -BPL. Only the Water Quality Control Commission has the statutory power
<br />to adopt water quality standards and classifications.
<br />Cotter does not understand what the Division means by "drinking water quality criteria defined
<br />by the WQCC." "Criteria" is a term of art under the Clean Water Act and does not have
<br />applicability here. See Colo. Rev. Stat. § 25 -8- 204(6).
<br />It should be noted that uranium in groundwater is pervasive in Colorado as well as other western
<br />states. Attached are two figures showing historical uranium concentration data collected prior to
<br />1981. These maps have not been updated to reflect the large body of information being collected
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