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1 <br /> <br />' Comment: <br />' 1. Need an update of Pink Gneiss activities (the DMG issued a partial ' prova] of the <br />pilot project on February 17, 2000), including a schedule for initiation of the project, <br />' a narrative describing any EPA requirements for additional wells in a Pink Gneiss <br />azea, and documentation regazding the well locations, completions, etF. Submit the <br />update to the Division by May 26, 2000. <br />' Response: <br />' BMRI anticipates initiating the in situ pilot-scale test in the Pink Gneiss P~t during May <br />2000. The EPA issued a letter dated February IQ, 2000 confirming that the ~ilot-scale test <br />' was authorized by rule as a Class V injection well. <br />' As part of the permit process, the EPA iJIC staff recommended that BMR~ consider the <br />installation of two additional groundwater wells in the Pink Gneiss Pit. The E]?~A request was <br />' based on two considerations: (1) EPA staff suggested that the post-treatm~rtt monitoring <br />should be based in part on water quality data collected from a monitoring well (located within <br />' the treatment zone, but from a monitoring well that was not involved with th~ injection and <br />' distribution of organic cazbon and (2} EPA staff suggested that an additional+downgradient <br />monitoring well should be placed between the Pink Gneiss Pit and the West Pit4 <br />' After review, BMRI concurred with the EPA recornmendation and installed Evvo additional <br />groundwater wells BF-11 and BF-12 (see map in Attachment A). The ground~ater well BF- <br />' 11 will be used as an injection location during the initial phase of the pilot-scab test, with the <br />original Pink Gneiss Pit groundwater monitoring well BF-7 maintained purely as a <br />' monitoring well. The advantage to this injection and monitoring plan is that $ lengthy prior <br />' history of water quality data exists for the monitoring well BF-7 such that changes in water <br />quality that derive from the addition of organic carbon can be unequivocallydemonstrated. <br />' The additional groundwater monitoring well BF-12 was installed to providd water quality <br />information downgradient of the main treatment zone in the backfilled porti~n of the Pink <br />' Gneiss Pit. <br /> <br />Resaurcet lnc. <br />1 <br />f Mi!(er, lnc. <br />May S, 1000 <br />