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GE®MA" RIX <br /> Section 20415 of Title 27 states that a DMP must have a sufficient number of monitoring points <br /> that are "installed at appropriate locations and depths to yield ground water samples from the <br /> uppermost aquifer," and that"provide the best assurance of the earliest possible detection of a <br /> release from the Unit." As seen on cross-sections A-A' and B-B' (Figures 3 and 4,respec- <br /> tively), the existing groundwater monitoring wells have screens that are about 20 to 50 feet <br /> below current groundwater levels (measured on October 5, 2000). The compliance wells are <br /> apparently screened below the uppermost part of the aquifer, and may be screened in two <br /> different water bearing zones, which are separated by a thick clay layer. <br /> In a December 18, 2000 meeting with RWQCB staff, Simplot proposed to install a new moni- <br /> toring well system to more fully comply with the detection monitoring provisions of Title 27. <br /> The RWQCB replied with a letter dated December 22, 2000, requesting the submission of a <br /> work plan by March 1, 2001 for the installation of additional monitoring wells and a <br /> background well. <br /> 3.0 GROUNDWATER OCCURRENCE IN EXISTING WELLS <br /> Groundwater occurrence in the existing monitoring wells has implications for the placement <br /> and construction of the DMP network. <br /> 3.1 GROUNDWATER ELEVATION AND DEPTH TO GROUNDWATER <br /> Since late 1994, groundwater elevations in monitoring wells adjacent to the surface impound- <br /> ments (LP-1, LP-2, and LP-3) have ranged from about -1 to 11 feet from mean sea level (fmsl) <br /> (Figure 5). During this time the depth to groundwater in these wells ranged from about 8 to <br /> 17 feet below ground surface (bgs). Intra-well groundwater level fluctuations have been about <br /> 6 to 7 feet. <br /> Water levels have been measured in several nearby monitoring wells (PW-1-48, PW-2-40, and <br /> PW-3-49, see Figure 2) since 1983. The historical groundwater elevation range in these wells <br /> has been about 12 to 17 feet (Figure 6). <br /> 3.2 GROUNDWATER GRADIENTS <br /> Current groundwater elevation data derived from existing wells implies that groundwater <br /> beneath the surface impoundments flows generally to the west (Figure 7). The gradient in the <br /> uppermost portion of the aquifer may be different because the effects of deeper pumping wells <br /> 1APROJECM741.000\6741-06.doc 2 <br />