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<br /> <br />GENERAL CHEMICAL AND CHURCH & DWIGHT'S OBJECTION <br />General Chemical (Soda Ash) Partners (a competitor of American Soda's), and <br />Church & Dwight, Co., [nc. in their Public Comment, dated May 17, 1999, to the <br />Application, state there exists a statutory requirement under Colorado Law that water <br />quality baseline data must be gathered for a period of five quarters before a Reclamation <br />Permit can be issued to American Soda. It urges this Board that baseline data cannot be <br />collected concurrently with the developmentofAmerican Soda's projectas outlined in the <br />Reclamation Permit Application. The objectors allege both drilling and development of <br />wells and well completion methodologies may cause groundwater contamination. None <br />of the statutory citations or rules citations contained in Objectors' comments support their <br />claimed requirement. Likewise, there is no evidence their concerns about water quality <br />degradation are well founded. <br />DMG STAFF REPORT RECOMMENDATIONS <br />The groundwater quality data collection method specified by the DMG is set forth <br />in the American Soda final Groundwater and Surface Water Monitoring Plan. This practice <br />based permit condition is approved by DMG as set forth at page 9 of its Staff Report dated <br />June 4, 1999 as attached hereto. In responding to General Chemical's comment as it <br />pertains to the requirement of water baseline data, the Staff Report states, at pages 7 and <br />8: <br />Rule 3.1.7(3)' specifies that permit conditions protective of ground <br />water be established for operations that have a reasonable potential <br />to adversely affect groundwater quality. Such permit conditions <br />may be in the farm of numeric protection levels. practice based <br />permit conditions, or both. As stated in Comment No. 20, the drilling <br />2 Colo. Code Regs §407-1, Rule 3.1.7(3): <br />(3) Procedures forestablishing permitconditions to protect the quality <br />of unclassified groundwater. <br />(a) New operations and modifications of existing permits: Any <br />application for a new operation, or an application for a <br />modification of an existing permit which modification has a <br />reasonable potential to adversely affect the quality of <br />unclassified groundwater, that is approved by the Office or <br />the Board on or after September ],1993, shall include permit <br />conditions pursuant to Parag_aph 3.1.7(21. [Emphasis added.] <br />AMERICAN SODA -2- BRIEFMC PAPER <br />