The following is an email from Heather McMurray to the Site Trustee.

Dear Mr. Puga,

Thank you for contacting me.

The storm water is not suitable for dust suppression — unless the Trust only tests for the chemical-analytes that the bankruptcy-court legally requires and/or the ones that the Trust has added. These do not look for actinide-metals and the low level radioactive waste isotopes — even though we know that the material went to the smelter, that it removed LLRW from the process water, and we have repeatedly asked for the data.

That storm water requires a pass through a Distillation unit that is rated to remove LLRW.

Please send me a picture (jpg) of the data-sheet(s) showing the max-daily 24-hr rain events. I live 3 miles from the asarco site and remember this year’s storms.

Is there a rain collection cylinder at the Parker Brothers arroyo?

We have traced the water feeding the Parker Brothers arroyo. Water from a huge area of the Franklin mts is directed to paved-culverts that meet in a single culvert that travels beneath the IBWC building and then empties to the beginning of the Parker Brother’s arroyo. That is a huge surface area funneled into a single flow. Doesn’t that water flow go immediately into the culvert that travels under I10 and the Asarco property. There must be engineering diagrams for those city culverts showing expected flow from various rain events. The flow in Parker Brother’s Arroyo cannot be simply calculated by the amount of rainfall on site.

We are concerned about the site runoff that always occurs down the unpaved-road from Asarco to Executive. The storm-water permit never declared water-discharge to Executive Drive. Also, we are concerned about the manholes and culverts on the Asarco site-proper that receive storm water.

The storm ponds at Asarco were built relatively recently, and water was allowed to accumulate in Rubber Lake until the 500 year flood event that caused the side of Rubber Lake to fail. Although that was shored-up with new soil (still visible from I10) rubber lake’s liner was compromised on that side. I have films of that, and there is also a film posted online. We have never heard if that liner can still-withstand a 100-year-flood-event as specified.

Visual confirmation for total rainfall is not effective unless you are visually confirming the water-accumulation against the proper measuring-scale (a rain collection cylinder) or can confirm amount of debris carried off (water flow).

Heather McMurray

Roberto Puga’s response:

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