2008-03-03_REVISION - M1988112 (21)

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Objection to SMRI's AM-03 Page 9 of 23 February 22, 2008 is totally avoided under the existing regime? Why weigh a potentially small chance of release against no chance of such occurring if there is no pipeline? Presumably the only reason.for abandoning the water treatment concept is cost. Whatever the cost consideration is currently in maintaining it, it must be weighed against the cost if the treatment facility is eliminated and there is a situation in which; (a) waste water with contaminants enter the aquifer downstream that otherwise would not be introduced into the aquifer, (b) injury or harm due to circumstances that were not originally contemplated; (c) the current drinking water standards of the aquifer are impaired; and/or (d) any of the assumptions in transporting the waste water or introducing the contaminated waters into to the aquifer are incorrect or otherwise fall. In short, Opposers submit that DBMS need not dwell on the technical considerations behind AM-03, if the ,policy considerations are not acceptable in principle. Here the policy considerations that BMRI assert are-not acceptable in principle and fail when It proposes to degrade the water quality in the aquifer over that which currently exists as a primary component of its concept. Attached hereto is the Engineering Report of Scott Mefford of February 21, 2008, as Exhibit E, which includes a prior report of June 4, 2007. Note that his 2007 report indicates that only certain constituents have been monitored in the past which is not inclusive. Other material constituents have not been monitored. He notes that calcium, copper, fluoride, iron, manganese, sulfate and totally dissolved solids all have secondary drinking water standards associated with them. None of the primary drinking water standard parameters were tested in these wells. Mr. Mefford notes further that the quality of the water in the West Pit area has improved in some instances but in other instances it has not. Iron, manganese, and TDS (total dissolved solids) consistently exceed the secondary drinking water standards in the West Pit wells. By comparison in both the Shalom Ranch Well and San Luis Town Well, iron is less than .06mg/l or about one order of. magnitude lower than even the secondary standard. Similarly, the manganese level in the Shalom Ranch and town wells is less than .04mg/I, well below the Secondary Standard limits. Fluoride and TDS in the West