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Musco Family Olive Company _ 19 - 12 December 2006 <br /> in groundwater quality as a result of specific groundwater conditions — i.e. a drainage swale <br /> that has the potential to channel and retain groundwater." The Report proposes to segregate <br /> the Ambient Groundwater Conditions into four distinct groundwater environments based on <br /> groundwater quality and gradient. The four environments include: the uplands area, the mid- <br /> gradient Swale area, the downgradient area, and the deep zone. <br /> The Report proposes to establish background concentrations for the four environments based <br /> on ambient concentrations of the four environments by calculating the average concentration <br /> through time. Proposed ambient concentrations for the four environments are presented in <br /> Table 9 below: <br /> Table 9 <br /> 4 Ambient Concentrations <br /> Compartment Compartment Ambient TDS Ambient Ambient <br /> Wells (mg/L) Chloride Sodium <br /> (mg/L) (mg/L) <br /> Compartment A MW-1 and MW-15 1,292 377 371 <br /> (Upland) t <br /> E <br /> Compartment B MW-13, MW-14, 2,465 792 573 <br /> (Mid-gradient) MW-16, MW-3, <br /> i MW-5 <br /> E <br /> Compartment C MW-11, W-2, 1,513 452 467 <br /> (Lowlands) MW-10 <br /> Compartment D MW-4, MW-7, 1,705 397 416 <br /> (Deep Zone) MW-8, MW-12 <br /> k <br /> Based on'a review of the July 2004 Report, Staff reject the segregation of groundwater <br /> environments and "Ambient Concentrations" proposed based on the following response to <br /> conclusions provided in the Report: <br /> a. Staff rejects the proposed segregation of groundwater environments based on <br /> groundwater quality and flow. Groundwater quality when evaluated from the uplands <br /> through the lowlands is characterized by elevated TDS, chloride, sodium, and <br /> bicarbonate concentrations and staff considers the groundwater environment beneath <br /> the site to include a shallow and deep groundwater zone only. <br /> b. The up-gradient origin of groundwater flow into the drainage swale and across well <br /> MW-15 is from the uplands area of MW-1 (Field 95). However, the Report implies that <br /> up-gradient water is the source of elevated TDS concentrations found in the wells <br /> associated with the drainage swale. Staff rejects this interpretation since TDS levels <br /> initially measured in well MW-1 were approximately 700 mg/L, below the current TDS <br /> concentration of 1,600 mg/L. The increase in TDS in well MW-1 is primarily due to <br /> .T <br />