2008-03-03_REVISION - M1988112 (21)

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Objection to BMRI's AM-03 ` Page 13 of 23 February 22, 2008 4). There is no analysis as to total dissolved solids in the report. Yet, Scott Mefford's June 2007 report attached as part of Exhibit E was submitted as part of these Opposers objections to the SWSP in June 2007. With knowledge of the issues raised by Mr. Mefford,. one would expect BMRI to have addressed them as part of AM-03. 5) The analysis as to manganese assumes that there will be no increased levels in the ground water after the land dispersal. The premise is that soils at the ranch are initially absorbed by the soil oxidized to forrn insoluble manganese oxides, and that soils at the ranch have a virtually unlimited capacity to retain manganese. Due to "multiple soil and pond geochemleal processes that remove manganese from solution", the report contends that no discussion of increased manganese concentrations in the ground water need occur as part of the land dispersal concept. The report states that manganese will initially be controlled by adsorption Into the soil, but is unclear as to what occurs after the initial period. (p. 32) Overall, the implicit assumption-behind the analysis is flawed as it assumes that: (1) there is an entitlement of some sort to steadily Infuse waste water into the aquifer that is of a lower quality standard than that naturally occurs; and (2) that one can, or should, ignore drinking water standards as to those inhabitants that rely upon the aquifer for their source of supply; as the town of San Luis and inhabitants in proximity to the town. Of greater concern is that the land dispersal concept is based upon a pyramid of assumptions with inadequate detail. If any one of them is faulty or fails, the pyramid collapses. THE LYTLE WATER SOLUTIONS, LLC, REPORT LACKS NECESSARY DETAIL AND BACKGROUND INFORMATION The undated report of Lytle Water Solutions, LLC, is.attached to AM-03 and contains a number of assumptions and contentions that merit examination. There is a glaring lack of detail in the report. MODFLOW is a three-dimensional numerical ground water flow model that, when coupled with MT3DMS, can provide