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r.. <br /> Antonia Vorster -2- 8 December 1989 <br /> On 17 November 1989 I received a phone call from Ms. Vicki Kretsinger of L&S. She <br /> indicated that chlorides were found at high concentrations in well 3B, indicating <br /> probable contamination of the deeper zone. Also, she said they were planning to video <br /> wells P4 and P5 next week to provide construction information. They plan to modify <br /> their workplan to propose the installation of 2 additional well clusters, and therefore <br /> the workplan would be delayed until sometime in December 1989. <br /> On a side issue, some erratic chloride data from some ground water samples has <br /> previously been attributed to inconsistent well purging. The April 1989 report also <br /> reported that nitrate concentrations have exceeded the Title 22 standard of 45 mg/L <br /> in several wells. Nitrate analyses should be included in the verification monitoring <br /> program along with the other constituents. A sampling/analysis plan should be prepared <br /> by SMS which details equipment, procedures and qualified persons to be used to collect <br /> and analyze samples in the future. <br /> PLANT REVISIONS <br /> The 25 October 1989 report reiterated SMS's plans to complete plant revisions to <br /> decrease waste generation and spillage, construct above-ground evaporation tanks, then <br /> close the surface impoundments. They propose to convert their salt handling to bulk <br /> loading by 1990. Since I observed an open salt bin with salt spilled on a dirt roadway <br /> during my 17 October 1989 inspection, I agree that improvements are needed without <br /> delay. SMS should explain how bulk loading will be an improvement over the current <br /> system. The October report also states that SMS has undertaken considerable efforts <br /> to reduce the waste brine flow by recycling. <br /> An asphaltic concrete (AC) pad has been installed under all the tank rows for the <br /> purpose of catching rainfall , spillage, and the waste brine flows. Based on my <br /> inspection on 17 October 1989, I do not believe the pads extend out sufficiently from <br /> the tank rows or have tall enough berms to catch and contain any spills should they <br /> occur. SMS also plans to pipe the waste brine directly to the disposal area, instead <br /> of flowing on the pad. A time schedule should be provided from SMS for upgrading the <br /> pad to provide adequate secondary containment and for plumbing the tank rows. <br /> The October report details an extensive surface drainage sampling program to evaluate <br /> if storm runoff from various areas of the facility are not impacted by operations, in <br /> an attempt to gain our approval to discharge those flows into the North Fork of <br /> Littlejohns Creek. The report indicates that SMS would like to directly discharge all <br /> rainwater runoff from the facility. I have my doubts that direct discharge can be <br /> allowed, since I observed a salt-like sheen on some roadways during my last inspection, <br /> and I believe the potential remains for spills to unprotected areas. I agree with <br /> SMS that the first major storms may carry the most contaminants, and I am, therefore, <br /> particularly interested in the analytical results from sampling the first major <br /> rainstorms around 23 October 1989, and 24-25 November 1989. Should SMS determine that <br /> storm runoff is contaminated, a soils sampling program should be implemented to verify <br /> the extent and magnitude of contamination. <br /> POND CLOSURE <br /> Should waste flows be reduced sufficiently by the above activities, the October report <br />