integration of these separate efforts to avoid having them become disjointed parts of an overarching task.

In view of the stated importance of the fate and transport of microorganisms to the ASR project, an advisory committee should be formed to assist with these aspects of the project. Dr. Ron Harvey, who has extensive experience in this area, is one of the Project Delivery Team members. Such a committee would be helpful in making decisions on these issues.

The PMP calls for independent technical review. However, the Independent Technical Review Team is to be made up of only representatives of USACE, SFWMD, and contractors. This constitutes in-house review, which may be sufficient for many tasks. Independent technical review will be an important component of the major tasks. For example, in Appendix H, Quality Control Plan, there are provisions to include outside technical experts in review of the pilot studies, but not the regional study. Outside technical experts should also be included on the Independent Technical Review Team for the regional study in order to enhance credibility and acceptance of the quality of the study. A study of the peer review process at the USACE by the NRC (2002) should provide useful guidelines in this area.

Section 7.8—Public Outreach and Involvement

Appropriately, public outreach is given high priority in the Regional Study, and the plan appears to be well conceived. Appropriate attention is given to environmental compliance as well (e.g., Endangered Species Act, National Environmental Policy Act), but this is generally not an issue because construction activities are a component of the various project implementation reports (PIR) rather than part of the Regional Study.

Section—Monitoring During Cycle Testing

The plan to over-pump during the first cycle beyond water quality limits and all the way to near 100 percent recovery of injected water is a useful strategy. This will allow the entire recovery mixing-curve to be established and used as a baseline.

Section 7.11—Operations and Maintenance

The Operations and Maintenance (O & M) plan to be developed through the regional ASR study apparently will cover only data logger systems for monitoring wells constructed as part of this study. However, additional O & M costs associated with these monitoring wells could be substantial depending on the level of monitoring undertaken during full scale ASR operation and the level of maintenance required for the monitoring wells. Even more substantial O & M costs will be associated with the operating ASR wells. For reference, the Las Vegas Valley Water District, with an average recovery cost of $191 per million gallons spends $13,000 per well per year in maintenance.

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