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JUN-19-1959 12 05 F:OTHf;;EF.BER JrHNSpri&LrpNS ~~% 6~B 52EZ P•1~ • • bot!>_ As is stand is Comment q20, the drilling and completion of wells has the patcatial m affeu gmuad water quality, The poreatial nSecn wnld occur due to ~~*~~~gllag of aquifers along the well hams. Na other acsiviIIes proposed daring developateat of the surface faalities have a reasonable potential to adversely affect ground water. The raroct permit coaditioas protective of ground water idapve to the potential for cotamingling alone a bore are practice based coaditiom. The tecltuaatiaa permit applieafioa requires the well casings be r*mvnted along their entire kagtb, and that a~teat logs be tun and mechanical iaugriry trstiag be coaducuA Paeh well eompletioa anrst be acetified and a constrnctioo report with all ]oggiag sad Iestiag rt_atilts provided is accordaaee with the regulations for Easiroameatal Ptometion Facilities (Rule 7.3) and the tams of the permit spplicatiaa Practice based permit coadirioas, by their nantte, do not rtquire water quality baseline or monitoring. The acfiriaes proposed in the permit applicadoa that may affect ground water and that will requite permit canditiotu ptottxtiYe of ground water in the form of numeria protection lends ue all rclsted W the rcquiremnnt m isolate production fluid from the aquifers. No production fluid wit] be generated until heated barren solution is injected iota the mining iatetval. Injxtion of solution is prohibited in the permit application until tho ground areter chazactetizatian study is campleu. 'T'hus the baseline grotmd water information collected during the study will be valid, pre-mining azabiem quality data a+hich can thrn be applied in the davelopareat of nuateric ptouction levels for oa-going moaitosia;, In objeciiao to the approval of the application, rho comtmentors state that DMG will be vulnerable to pressure m establish less stringent standards if the standards ere established after Wa project is underway. Howevrs, there i5 no subjgetiviry in the establishment of numeric protection levrls. If the srnbient quality is at coarratratiaas lower than the grauad wader 6gndard far a particular parameter, thm the standard becomes the protection kveL Tf the ambient quality is u coaceattation is creaser of the standard, due m natural or pre-otistiag anthropoganic con*~**;~efioa, rhea the numeric protection level is set at the ambient quality. This narrative standard, as well as the tabte value ctandatds for grrnutd water aze established by the Colorado Wsrrs Quality Control Commission Also, is the ease of the AtarJrca~a Soda proposal any detectable release of production thud to ground water would require cotreetive action, mgardless of whathar ground water standards art: czraded. Based oa the fowgoing diaeuasiaa, is is not necessary to delay dwelapmeat of strrface facilities at the Yankee Gulch Project m collect the required five quarters of ground water baseline iafotmatian. 5trelt a delay would not ittrpmve in nay way the DMG's ability to require permit condilians pIntCCtive ttf the ground water resatece. Comment #21 Disposal well iaf]veace oa baseline dud DMG Bsnpatu~ The disposal well is operated under an uttdergnund iajectian cantroi suthariration from HPA uarnlated to the solution mining activities proposed is the reclamation permit agplicaaoa. Any affect oa ground water eatued by the operation of the disposal wen would be a eomponeat of the pttaniniag baseline condition. No disposal wells aze proposed in the mclaraatioa permit application uadar coasidtaation.