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~ III IIIIIIIIIIIIIIII ~ <br />Date: I /31 /00 <br />To: Jim Dillie /~ <br />From: Jim Stevens ~`7 <br />Re: BMRI proposals in regard to establishing a second Point of Compliance for the Rito Seco alluvial aquifer <br />1 re-read the BMRI original proposal, dated 1/3/00, and combined that with the revision of that proposal dated <br />(/19/00. My concerns with the revised proposal are as follows: <br />I) Location: The proposed location of the new Point of Compliance is some 2400 feet down gradient from <br />contaminated M-I IR and approximately 2000 feet from uncontaminated M-26. That really isn't very close to <br />the area of contamination in the alluvial aquifer, a relationship which, in itself, could give us a regulatory <br />problem in defending it. An additional complication is that according to the BMRI map sent with the 1/19/00 <br />revision, two surface drainages cross the alluvial aquifer from the north and enter the Rito Seco up gradient, <br />i.e. east of the proposed POC. As a result, whatever contaminants these drainages might carry fromi the north <br />could enter the alluvial aquifer up gradient of the proposed POC and possibly create an excursion at the POC <br />or at least complicate the interpretation of one. (I know you believe only one drainage enters from the north but <br />[heir map shows two and if its wrong, it too should be corrected since i[ is part of the proposal.) <br />2) Depth: I would recommend requiring that the proposed POC penetrate S to 10 feet (your choice) into the <br />underlying Santa Fe orpre-Cambrian, have at least 10 feet of saturation and be able [o consistently yield water <br />samples. <br />3) Log: I agree [hat we should have a specific proposal in regard to the drilling and completion of the well. Then, <br />as a follow-up, 1 would recommend that we require a li[h or drillers log that describes the section penetrated <br />and demonstrates that the drilling and completion requirements were me[. <br />4) Permit conditions: They have proposed that the samples be analyzed for a full suite of constituents consistent <br />with what is now being done, which is acceptable. 1 would, however, recommend that those paramgters to <br />serve as permit conditions be clearly identified in the proposal. (I have no problem with employing those <br />specified in TR-IS for M-I IR.) <br />5) Method employed in setting permit conditions: BMRI has proposed taking at least 8 groundwater gpality <br />samples over a 5-quarter period, which is acceptable. They have not, however, specified what apprgach will be <br />employed to set the numerical values of the permit conditions themselves, i.e. the Dixon method fon <br />consistency or something else. (We did use a different method for CC&V is setting [he numerical values so I'm <br />not adverse to considering achange/improvement.) <br />6) Sampling: I would agree that sampling protocol should be consistent with what is already in place. Of that <br />protocol is described in TR-6, fine. <br />