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Ms. Lori Potter ~nC November 3, 1999 Page 2 Section 2.1. Paee 4. Paraeraph 1, Lines 3 throueh 6 In TR-26 (page 66), a pumping rate of 200 gpm was predicted to result in a 15-foot water level decline in the West Pit aker 150 days. In an August 27, 1999 letter from Mr. Ron Zumwalt (BMRq to Mr. Jim Dillie (DMG), the five "window" wells were being pumped at a combined rate of 99 gpm; there was no report of the backfill wells being pumped. Apparently, the continued pumping of the wells between July and mid-September only yielded a one to two-foot decline in the West Pit groundwater level. These data reinforce the fact that TR-26 does not adequately characterize the site hydrogeology (see previous comment). What is the revised forecast to achieve the target groundwater level? How does this time frame fit with the Cease and Desist Order schedule? Section 2.1, Paee 4. Paraeraph 2. Last Line Again, the West Pit groundwater extraction system was to lower the groundwater level in the West Pit 15 feet aker operating forl SO days at 120 gpm. In reality, the water level has only declined one to two feet under this operating scenario. The current document states that groundw~.ter will be extracted at a rate of 400 gpm. Please specify which wells will be pumped and their pumping rates. Please provide the production rates for these wells since July, 1999 to demonstrate that these wells can achieve the combined target production rate of 400 gpm. Section 2.1, Pretreatment Stage, Paee 5, Paraeraph 1, Line 13 The addition of hydrochloric acid and anti-scalent reagents described here are not illustrated on Figure 2-1. Please add them to Figure 2-1. Section 2.1, Post filtration Staee, Paee 7, Ton Two Lines The quiescent tank volume requirement of 5,000 gallons fora 30 minute residence tirne is not consistent with the reaction tank that feeds it (see page 6). The reaction tank is specified as a 2,000 gallon tank with aten-minute residence time. Following the reaction tank ratio of 20(t gpm of residence time, the quiescent tank should have a 6,000 gallon capacity. Section 2.1, Sludee Handline Stage, Paee 7, Line 3 What will happen to the "entrained water"? Section 2.1. Concentrated Reiect Handline Stag/ Paee 7 The flow path for this waste stream presented in Figure 2-1 doesn't include either of the ponds discussed, but is does show this water going to the "discharge effluent" and "reinjection of concentrate". Please clarify.