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MASSEY SEMENOFF Sy STERN, P.C. <br />Mr. Doug George <br />May 5, 2000 <br />Page 3 <br />supporting documentation whatsoever. We note your assertion that your client has <br />"investigated the problem thoroughly by the involvement of well experts and others," and <br />thus, we believe [his information should be provided to BIvIRI for review to evaluate the <br />contention that loss of production in this well is somehow related to BMRI operations. <br />Without any such documentation being provided by the Shalom Ranch's well ~:xpert, it is <br />impossible for BMRI to evaluate the causes of the purported reduction in production at <br />this Shalom Ranch irrigation well. There has been no evidence provided that any of <br />BMRI's actions have any bearing on the production decline at the Shalotn Ranch's <br />irrigation well. In fact, given the history of having to replace irrigation wells at this <br />location, we have been advised that it is entirely possible that productior. has been <br />deteriorating over time and that this well is simply in need of replacement again. <br />From a water quality standpoint, BMRI has been obtaining water quality samples <br />at the Shalom Ranch domestic well since January 30, 1991 as part of the settlement in <br />Case No. 89CW32 with the Dos Hetmanos Ranch (the former name of the Shalom Ranch <br />property). When our experts reviewed the pazameters of concern which are noted in your <br />letter in the database for the domestic well at the Shalom Ranch, there are no indications <br />whatsoever of water quality degradation for any of the pazameters listed in yore letter. In <br />addition, the observed concenvations of each of these constituents is at, or below, the <br />maximum contaminant level (MCL) for drinking water, with the exception of iron and <br />manganese concentrations observed in 1992. Given neutral, to slightly alkaline, pH <br />values at this well, and the relatively low concentrations of the pazameters cited in your <br />letter, there is nothing in the water quality data base to indicate the type of <br />corrosion/encrustation to be occurring in this irrigation well that you assert (except as it <br />relates to reactions occurring due to the introduction of oxygen). We would also request <br />that if you or your client have any additional water quality data that would :support the <br />contention that water quality changes from BMRI's operations has t:aused the <br />degradation in production at this irrigation well, we would like to review these data. <br />In conclusion, we currently have no data to evaluate the timing and/or degree of <br />deterioration in well production, the condition of the casing and/or perforations, or water <br />quality conditions which would affect the performance of this well. Therefore, we have <br />no basis to conclude that BMRI's operations have had any effect on water quality at the <br />Shalom Ranch imgation well that has played any part in the purported dete:zoration in <br />production at this well. Given the history of the Shalom Ranch irrigation wells having to <br />be periodically replaced, the current deterioration may simply be related to the natural <br />deterioration of a well which has already occurred in the past at this location. We would <br />note that our conclusions in this regazd are consistent with the response you have <br />