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pattern ofdamagc seemed to indicate a discharge of Itiglt TDS water, not just a mist. I would like to revisit the site in Ure company of BLM personnel and verify the extent of damage and confer with the BLM Staff to determine whether remedial action for the soil should be initiated. Note that repacking the leaking swivel assembly is not remediation, it is correction oC an equipment failure; the RUE does not specify any remediation, including simple toting of Ure area for contamination, other than lran•esting trees. Unless other actions have been initiated, this is not an acceptable response to the damage caused b}' this RIDE. item 3: Has BLM reviewed and analyzed the water quality data for the alluvial well (Well 21-2) downstream of the pond which was designed to monitor pond integrity? The following table summarizes the data from Well 21- 2, based on the information provided in Attachment 3 to your April 1, 1999 letter. Well 21-2 (Alluvial Wcll)• *All data are in parrs per million (ppnt), M/D=missing data Date Bicarb Total Dissolved Solids Chloride 12-22-98 2,671 2,292 56 11-22-98 2,806 2,285 26 09-21-98 1,512 1,885 27.9 06-29-98 I,Sl2 1,500 28 03-03-98 2,016 M/D 102 12-I1-97 1,092 M/D 16.3 06-10-97 929 1,530 ]~ These data clearly indicate a trend towards poorer water quality downstream of the pond. II is not clear what is qusing Ure degradation of water galliq~ (500 ppm increase in TDS and 1,732 ppm increase in bicarb), but it is substantial and the only known source would be the pond or upstream extraction wells. Given the substantial increases in Biaarb during Utc last hvo monitoring dates, the first source that comes to mind is the release of m•Otcolite or Ure dischrrged water in Uie pond which may have entered into the alluvial groundwater aquifer. BLM should have initiated an investigation into the cause of this degradation, and if such an investigation Itas not been started, then it is essential that one be initiated. This is the aquifer that should direrily feed Piceance Crcck and its degradation will result in subsequent degradation of surface (lows in the Creek. The cause, extent and characteristics ofdegradation must be examined and if necessary, corrected _ through remedial action on the part of American Soda. Item 4: In response to your comments regarding American Soda's construction activities meeting BLM's erosion control requirements. I reviewed these requirements under BLM's 9113 guidelines. These Guidelines state: a) road crown, the road should be crowned to ensure proper drainage. b) inslope or outsloped roads may be used if grade does not exceed 6%. c) cut and fill slopes steeper than 2:1 in level and rolling terrain or 11/2:1 in mountainous terrain must not be used. d) side ditches collect the runoff from the roadway from adjacent upstream areas. e) turnouts arc provided on single-lane roads, normally spaced at a maximum distance of 1,000 feet. n drainage culverts are used for all minor drainage crossing. Culverts arc designed to pass a 10-year storm flow. g) very lovccolwne resource roads that arc outsloped or insloped are usuall} the only type that may utilize fords. As slated in my letter of February l7, 1999, I did not see evidence of compliance with the above guidelines during my field visit in 1998. Erosion control measures should have been constructed during road construction at U~at time and were clearly not in place. I also did not observe segregated topsoil storage areas.