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2.4 Monitoring Reports <br />The end of the "water year" is September 30th. The monitoring reports are submitted <br />annually and generally nine months after the end of the water year. This report is <br />submitted to the BLM in the NS annual report. Pursuant to BLM stipulations, NS will notify <br />the Authorized Officer within 10 days of the occurrence of any significant changes to the <br />hydrologic system. <br />3 Subsidence Monitoring Plan <br />The Natural Soda LLC subsidence monitoring plan includes both surface and subsurface <br />monitoring of the potential vertical ground movement on the NS Lease. Subsidence <br />monitoring will be performed throughout the commercial operating life of the solution <br />mining operations and for a period of three years following cessation of mining activities. <br />Results of the subsidence monitoring (both surface and subsurface) will be checked <br />periodically as needed, to verify and calibrate numerical models used in the design of the <br />well -field layout. Surface subsidence monitoring will be conducted by establishing <br />permanent surveying monument locations. Subsurface monitoring will be conducted by <br />periodic borehole geophysical logging of the well bores and strata overlying the cavities <br />produced by the solution mining activities. <br />Pursuant to BLM and EPA stipulations, NS will perform the following activities. <br />• Survey for surface subsidence on a biennial basis. <br />• Pursue appropriate methods to determine cavity configuration. <br />• Determine extent of caving when noted. <br />• Attempt to determine impacts on USDW aquifers from caving or pillar failure. <br />Prior to implementation, the revisions and updates to the plan will be submitted to the <br />appropriate agencies for review and approval. <br />3.1 Subsurface Monitoring <br />The purpose of the subsurface subsidence monitoring is to ascertain movement of strata <br />overlying the solution -mined cavities. Borehole geophysical techniques will be employed <br />for determination of potential subsurface movement of the overlying strata. In pre-existing <br />solution mining areas south of the plant (Figure 6) (historical Panel 1) and south and east of <br />the plant (historical Panel 2), Time Domain Reflectometry (TDR) was employed. Currently, <br />NS monitors these TDR locations on a monthly basis. In addition, an independent third <br />party monitors the locations on a quarterly basis. This method of subsidence monitoring <br />has proved to be problematic and unreliable. This method is not as robust as was originally <br />Daub & Associates, Inc. <br />Page 12 Natural Soda LLC 2015 EMP <br />