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' SEP 05 '69 13:43 LUHDOPFt CALMANINI WOODLAND P.6./10 <br /> 2 <br /> While the UIC application was being reviewed by EPA, the Briners were faced with <br /> compliance with Subchapter 15 requirements to monitor subsurface conditions in the <br /> vicinity of the evaporation ponds. To address Central Valley Regional Water Quality <br /> Control Board (RWQCB) concerns regarding potential ground-water degradation at <br /> SMS Briners, and to address ground-water monitoring while the in well permit <br /> Process was proceeding, I.SCE developed an interim ground-water monitoring network <br /> and program. The interim monitoring program, which was approved by the RWQCB, <br /> was designed to be of limited extent and duration, using existing wells and a single new <br /> dedicated monitoring well, with water quality analyses and water level measurements to <br /> be obtained from the well network until the injection well question was resolved and the <br /> future of the ponds determined. <br /> Since receipt of the EPA recommendations to withdraw its LTIC permit application, the <br /> Briners have remained intent on ultimate elimination of the evaporation ponds, although <br /> the pursuit of a deep test hole, without some assurance that an injection well could be <br /> subsequently constructed, has been deemed uneconomic. Consequently, with the <br /> injection well project now abandoned and the interim monitoring program operational <br /> for almost two years, this report has been prepared to review the initial results of that <br /> program and, as a result of the findings of the monitoring thus far, to propose further <br /> site investigation and revisions to the monitoring network and program. Also included <br /> in the report are recommendations for modifying wastewater handling on site to allow <br /> the ultimate closure of both existing evaporation ponds. The latter proposal would be <br /> phased over a four year period to allow generation of financing from ongoing <br /> operations; and it includes certain activities which are part of the Briners' regular plant <br /> operation and maintenance, and which have consequently been initiated. <br />