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Page 3 • • <br />Mr. James C. Stevens <br />June 25, 1942 <br />Since the location of Well M-9 is fixed, <br />M-13 and M-14 should be relocated to <br />provide greater breadth of coverage for <br />east to west flow as well as to provide an <br />apparent ability, comparable to that of <br />M-9, to monitor for containment leaks from <br />the pond and/or tailings facility. <br />BMR Response <br />The concerns addressed in this comment are based on the <br />potential coverage provided by wells M-9 and proposed wells M- <br />12 and M-13. It should be kept in mind that the primary <br />function of the installation of wells M-12 and M~13 is to <br />establish three monitoring points (including monitoring well M- <br />9) whereby the local groundwater gradient can be triangulated, <br />and to develop local aquifer hydraulic characteristics to <br />evaluate the effectiveness of these well locations to <br />adequately monitor downgradient of the tailings facility and <br />collection pond. Therefore, this comment seems to be premature <br />in that the initial data collection has not been done to <br />evaluate whether wells M-12 and M-13 are in optimum locations <br />for contaminant leak monitoring. To make the changes suggested <br />by Mr. Stevens in this comment would result in lesffi optimum <br />data to determine the local groundwater gradient. Therefore, <br />it is BMR's position that these well locations should be left <br />as is at this point in time, the initial data colledted from <br />these wells and an assessment done as to whether th@se wells <br />adequately monitor potential leakage from both the tailings <br />impoundment area and the collection pond. <br />Division Comment No. 3 <br />The Santa Fe Formation, which comprises <br />the first significant aquifer below the <br />collection pond and tailings facility, is <br />a unit with considerable lithologic <br />variability. Individual beds within the <br />formation are highly lenticular. It is <br />useful for purposes of understanding the <br />hydrogeology of the area, determining the <br />adequacy of the monitoring, and evaluating <br />the remediation potential of the proposed <br />monitoring network, that correlations and <br />characteristics of the Santa Fe beds be <br />established for the area in question. <br />Such correlations, etc. might be more <br />easily made if the proposed drill holes <br />were geophysically logged. Reportedly, a <br />