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<br />• Page a <br /> <br />December 23, 1998 <br />method of reporting, and length of post-closure monitoring period will also be established. <br />The obvious choices for points of compliance are the two downgradient wells that are in <br />place. The numeric protection levels will be set according to the Interim Narrative Standard <br />for ground water adopted by the Water Quality Control Commission which is [hat quality <br />which meets the most stringent criteria set forth in Tables 1 through 4 of the "Basic <br />Standards for Ground Water" or the ambient quality, whichever is less restrictive. Upon <br />establishment of points of compliance and numeric protection levels, a compliance plan will <br />also be required. Enclosed with this letter is a copy of the DMG's standard ground water <br />compliance protocol. <br />In addition to the ground water protection program discussed above for the newly proposed j <br />CKD disposal area, the DMG will require that a ground water quality evaluation grogram be <br />implemented for the existing CKD monofill. ~ olnam must provide a plan for the <br />characterization of ground water quality downgradient from the existing monofill.]This plan , <br />will be subject to Division review and approval prior to implementation. In the event that <br />ground water contamination is detected, the limits of the contamination will have to be <br />investigated, and numeric protection levels and points of compliance established. Also, the <br />presence of ground water contamination below the existing monofill would necessarily trigger <br />a review of the design and operation of the newly proposed CKD disposal area. Conversely, <br />if no contamination is found below the existing monofill, such a finding would serve to ratify <br />the conclusion in the "Hydrogeologic and Geochemical Assessment" report that it is <br />extremely unlikely water migrating from the disposal facility would reach a drinking water <br />supply. , <br />The current decision date for technical revision TR-03 is January 11, 1999. I~ order to <br />provide Holnam with sufficient time to respond to the issues listed in this letter, and to provide <br />for an opportunity for DOW to evaluate the site, you may wish to submit a letter to ~;stablish a <br />later decision date. <br />If you have any questions, please contact me. <br />Sincerely, <br />Allen C. Sorenson <br />Reclamation Specialist <br />~~___~. <br />c:\windows~personaMol iam3.doc <br />