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JUN-19-199? 12 04 F.OiHGEF.BEP. JOHNSON&LYONS 3A7 538 5252 P. 10 <br />may not be in the direction that the Monitoring Progam study design has assumed. And, changes <br />in the concemrations to 6e monitored have followed General Chemical's expression of wncem <br />about the reporting levels initially contained in the Monitoring Progam. <br />As important, American Soda continues to conduct pilot plan operations. These <br />operations themselves may affect goundwater quality. This should not be a possibility under the <br />plain language of the Colorado Mined Land Reclamation Act, which both requires a permit in <br />advance of Honing operations, and which specifically defines mining operations to include <br />developmental activities such as a pilot plant. The wntinued existing operation of the American <br />Soda pilot plant is a point that was explicitly raised and ignored in General Chemical's letter of <br />May 28, 1999, <br />Further, while the DMG has characterized the Monitoring Program as °rigorous" in <br />response to Comment 11, the third party validation by USGS appears to be limited to hand{ing <br />and testing of samples, not to proper completion of wells, or to an evaluation of other potential <br />defects in the Monitoring Program. If bad data is caused by errors in the completion of the <br />monitoring wells, for example, these errors cannot be cured simply by rigorous handling and <br />testing of samples. They can only be cured by proper completion of the monitoring wells, which <br />in turn may require more than satisfying the performance-based standards far well construction <br />which are designed to prevent commingling of aquifers. <br />The potential for errors unrelated to USGS handl'mg and testing is enhanced by the Fact <br />that American Soda bene5ts from testing which establishes poor ambient quality. As the DMG <br />