SITE INFORMATION AND CORRESPONDENCE

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Antonia Vorster -4- 24 May 1990 negatively impact the ground water plume, and to not redistribute pollutants over adjacent agricultural land, and result potentially in a much more costly and lengthy cleanup action. A proposal should be submitted for our review prior to any new well installation. C: SURFACE WATER 1. San Joaquin County staff estimated that a 2 inch storm would generate flow in the North Fork of Littlejohn's creek. Therefore, the creek should be evaluated as a flowing creek, as it probably flows in most normal , wet years. SMS should collect records from the Army Corp of Engineers or the County, to get historical records of when the creek has flowed in recent time. 2. Page 16 of the report says that additional creek monitoring was conducted to determine if adjacent irrigation drainage water was influencing the quality of water in the creek, but no discussion of the results was provided. If the results are those of samples collected in locations identified as E and W Creek 100, 1000, and 2000, respectively in Table 10, it appears that irrigation drainage waters have had an insignificant effect on the water quality , compared with the SMS site. 3. Figure 4,the drainage basin in the vicinity of SMS Briners, is not legible. An improved map, clearly showing drainage locations and flow capacities should be provided. 4. Page 34 of the report indicates that location C1 has shown increased chloride concentrations and may not always be representative of background concentrations. If the creek does not always flow, then constituents might be expected to mix in an upstream direction. Sampling stations E Creek (50) , E Creek (1000) , and E Creek (2000) show fairly consistent TDS and chloride concentrations (means of 237 and 12 mg/L, respectively) and therefore could better represent background concentrations. D: OPERATIONAL REVISIONS/SOURCE CONTROL 1. The asphalt/concrete (AC) pads under the process tank rows have not been proposed to be upgraded to provide adequate secondary containment for brine solutions, as was requested in our letter of 8 December 1989. 2. The report states that overflow lines will be installed 1 inch below the surface of each process brine tank to prevent overflow onto the AC pad. One inch does not provide a sufficient safety margin. SMS should propose a new timeline to install overflow lines, which should not have to take 16 months to complete. 3. SMS proposes to install their old wooden containers on an AC pad for evaporation of brine waste and rinse water. The report estimates that 328 tanks will be required to evaporate the estimated 430,000 gallons of brine wastewater generated annually. The water balance did not consider the reduction in evaporation which occurs in highly saline solutions, and so the surface area (number of tanks) required is likely to be significantly higher. The area indicated on figure 32 does not appear to be large enough to provide space for a sufficient number of tanks.