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Antonia Vorster -5- 24 May 1990 <br /> 4. The report proposes the additional surface sealing of the brine making area to <br /> facilitate the segregation of potentially contaminated storm water. The evidence <br /> to date indicates that the entire brining area is a source for potential surface <br /> and ground water contamination. The entire brining area, including roadways and <br /> brine making area, should be sealed, and all the flows should be collected for <br /> proper disposal . <br /> 5. The report proposes that SMS resubmit the injection well permit application to EPA <br /> for review and approval . I notified Vicki Kretsinger, of Luhdorff and Scalmanini , <br /> on 9 April 1990, that there may be problems in obtaining a Class 1 UIC permit. <br /> Another facility in the area had recently completed a deep injection well to 4500 <br /> feet and found the total dissolved solids were less than the required 10,000 ppm. <br /> Ms. Kretsinger indicated tkey were not currently planning to pursue a well to that <br /> great a depth. It appears that SMS may apply for a Class 5 permit instead. <br /> 6. The report proposes that both of the ponds at the site continue to be used, without <br /> any improvements, for disposal of contaminated storm runoff from the brining areas. <br /> Once an injection well is completed, the fluids are planned to be injected. At <br /> that time, the south pond is proposed to be closed and the north pond is proposed <br /> to be investigated and rehabilitated (by the summer of 1992) . The north pond will <br /> be required to meet Subchapter 15 standards, including appropriate liners and <br /> ground water monitoring. It does not seem reasonable to postpone this necessary <br /> source control work for two years. <br /> E: MONITORING <br /> 1. Quarterly nitrate analyses should be added to the monitoring program for all wells <br /> to assess if the operation is having an impact on the high nitrate levels observed <br /> in several wells in the vicinity. <br /> 2. SMS should conduct weekly water level measurements to assess the gradients and <br /> pumping influences, since they are so dynamically changing. <br /> 3. Pumping records should be maintained for all the production wells in the vicinity <br /> of the operation. <br /> 4. It is not clear exactly where the SR1 and SR2 drainage areas are located. These <br /> should be better defined. <br /> 5. Storm events should be correlated with flows in the North Fork of Littlejohn's <br /> creek to assess the frequency and impact of flushing flows on surface water <br /> contamination. <br /> PHL:pl <br />