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Objection to BMRI's AM-03 <br />Page 8 of 23 <br />February 22, 2008 <br />quality with elevated' constituent concentrations over that which currently exists has <br />been addressed with BMRI. ' (See Wallace Erickson's letter to William Lyle of BMRI <br />dated May 4, 2007) Currently, the problem is easily remedied near its source. <br />(d) Downstream monitoring locations provide a viable means to detect a <br />problem. Early detection allows for a timelier ability; and an easier ability, to remedy a <br />problem. <br />BMRI proposes to totally abandon the water treatment facility. It then proposes <br />to move the treatment process approximately three miles downstream for land dispersal <br />on agricultural lands. If allowed to do so, the treatment concept would be spread over a <br />much wider geographical area. It also targets an area that, potentially impacts other <br />parts of the community that would, in all likelihood, otherwise never be impacted by <br />West Pit waste waters. It Introduces waste waters into agricultural lands. It introduces <br />waste waters into the underlying aquifer that is the source of supply for irrigation of the <br />Shalom Ranch as well as the town of San Luis and other domestic wells. <br />BMRI's proposal means that a number of assumptions must be in place and be <br />accurate at all times, both in prediction and performance, in order to avoid a problem. <br />There are a number of serious concerns with BMRI's proposed approach: <br />(a) Sprinkler irrigation with the waste water assumes a release of those <br />waters into the air and ground water supply. of the aquifer. Use of the sprinklers <br />provides that 15% of the injected waters reach the aquifer and another 5% Is dispersed <br />through the air. (p. 24) <br />(b) The inhabitants of San Luis and neighboring areas use waters from <br />this aquifer as their source of supply for drinking water. It makes no sense to increase <br />the risk of injury and health considerations to persons, even minimally, when the action <br />is easily avoidable. <br />(c) The risk factor goes up substantially simply because of the <br />distances involved in transportation of the waste waters by means of pipeline from the <br />West Pit area to the point of dispersal: - approximately 3 miles. Why expose the length <br />of the pipeline to an unauthorized release due to miscalculation or error when the issue