MONITORING ALTERNATIVES

The following monitoring alternatives were developed for consideration as
supplemental to theA
monitoring plan proposed by Exxon.

Pipeline Monitoring - Inspections of wear-prone test sections of the tailings
pipelines would se
an indicator of the condition of the rest of the pipeline. With this approach,
critical points coti
monitored more frequently thus limiting the need for direct inspection of
the entire pipeline ei

Groundwater Drawdown - Alternatives to the proposed drawdown-related monitoring
program
of reducing or expanding the scope of the monitoring program. Reducing the
number of monito
locations and/or the frequency of monitoring would be less costly but would
not generate data
sufficient for making reliable impact assessments. Expanding the scope of
the monitoring pros
especially by increasing the number of monitoring wells, would provide a
more reliable data by
assessing project impacts. Indiscriminate additions, however, may not be
justified in terms of
added cost versus the marginal increase in data reliability. Limited adjustments,
such as addict
relocating monitoring wells in specific areas of interest, may be beneficial.

Groundwater Quality - As with the drawdown-related monitoring program, alternatives
to the
groundwater quality monitoring program center mainly on reducing or increasing
the scope of
program. Reducing the program is not acceptable because the reliability of
the data base wO4
compromised. Limited increases in the number of monitoring locations may
be justifiable and
beneficial. Additional well locations have not been identified.

In addition to altering the scope of the groundwater quality monitoring program,
alternative
of monitoring not proposed by Exxon can be considered. These include installation
of a colle
lysimeter beneath the preproduction ore storage pad in lieu of a monitoring
well and conductI
periodic physical and chemical tests on tailings in addition to the proposed
leachate sampling<

Heavy Metal Concentrations - A program to sample soil, vegetation, and representative
sma
mammals for heavy metal contamination from particulate deposition also could
be conducted
downwind of potential dust sources other than tailings ponds Ti and T2. These
samples could
collected in a manner similar to that required for the tailings pond.

An alternative sampling program for the tailings ponds would collect samples
along permane
(primarily downwind) transects located on Exxon's property. These samples
could be collect'
the growing season each year for the first three years from permit issuance
(background), th
five years of operation, and the last five years of the operation of Ti and
T2. These soil, ve
and selected animal tissue and/or organ samples could be analyzed for zinc,
copper, lead, m
total chromium, arsenic, and cadmium. This alternative would delete the proposed
monito
mercury, selenium, and silver. The alternative program would sample for a
longer period of
over a greater portion of the downwind landscape. Monitoring cost increases
would be parti
offset by the decreased number of parameters being analyzed.

Monitoring Alternatives for the Swamp Creek Discharge - The WPDES permit
could require X
monitoring of bismuth, platinum, and tin for the discharge to Swamp Creek.
Sampling for t
elements at the wastewater discharge lagoon outlet could occur monthly on
a 24 hour comr
sample. Monthly testing may be reduced after one year dependent on results
obtained and
information available on the toxicity of these metals. Samples also could
be collected semis
at the Swamp Creek outfall.

Sampling of the benthic organisms downstream from the discharge could be
done three times
(early spring, summer, and fall) rather than the twice annually proposed
in order to more ac
evaluate impacts.

The bioassay study to evaluate the impacts of heavy metals from the discharge
is proposed
An analysis on a quarterly basis would provide a greater amount of data to
analyze effects o
metals accumulation.                                                    
      .



Fish sampling and whole fish analysis in the laboratory is proposed for heavy
metal analysis.
of fish fillets rather than the entire fish could be more representative
for metals analysis.
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