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Dan Mathews <br />Page 2 <br />April 17, 2006 <br />for laboratory analysis during the period December 1977 through April 1979. Since this time of <br />baseline data collection, no samples have been collected for laboratory analysis. Field <br />parameters only are measured for the wells in the current monitoring program. I have the <br />following specific comments regarding the presentation and analysis of groundwater data. <br />3. The baseline groundwater data for the Alluvial Wells No. 1 through No. 6 is presented in <br />the McClane permit in Tables 4.2-1 through 4.2-5. There appears to be some baseline <br />data missing or possibly it was never collected. The current minimum requirements for <br />baseline groundwater information aze given in Rule 2.04.7 (1). No data are given in <br />Table 4.2-1 through 4.2-5 for Alluvial Well No. 3 (possibly dry), and iron and manganese <br />analyses are not provided for Alluvial Well No.s 5 and 6. No baseline data could be <br />located for newer wells GW-7 and GW-8. <br />There is also uncertainty as to which of the original alluvial wells (for which baseline data <br />has been provided) correspond to the wells in the current approved program. In the <br />Munger permit, Table 2.5-1 lists groundwater monitoring site numbers and corresponding <br />well numbers but this does not cleaz up the confusion regazding which of the "GW" wells <br />were monitored during the baseline data program. For wells in the approved program, it <br />is unclear if Alluvial Well No.s 1 and 6 correspond to GW-1 and GW-6, respectively. <br />Well GW-3 appears to correspond to Alluvial Well No. 2. <br />Because the alluvial sediments associated with East Salt Creek have been designated as <br />an alluvial valley floor, certain surveys and geohydrologic data are required. Please see <br />Rule 2.06.8 (4)(c)(iv). At a minimum, well completion logs and drill logs should be <br />submitted for all monitoring wells that are included in the approved monitoring plan. If <br />sufficient data exist, a groundwater contour map should be developed and updated <br />annually with the future AHR submittals for East Salt Creek Alluvium. Figures 4.1-3 <br />through 4.1-6 present boring logs (with well completion information) for four of the <br />alluvial wells, which appear to correspond to GW-2, GW-3, GW-4, and GW-5. No other <br />well completion logs or drill logs are presented in the permit document or AHR for any of <br />the other monitoring wells. <br />To clazify these discrepancies, the Division recommends that a new appendix be inserted <br />into each permit or modify the existing documents with updated information succinctly <br />presenting the approved groundwater monitoring programs. The nomenclature for each <br />well should be cleazly identified and the corresponding baseline data, drill logs and well <br />completion information provided. The water sample location map (Figure 4.2-2) should <br />be updated accordingly and if appropriate a groundwater contour map should be <br />developed for the East Salt Creek Alluvium. Please include in the updated appendices, a <br />well completion summary table of active monitoring wells. Please include in the table at <br />a minimum the following information: surface elevation, measuring point elevation, type <br />