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<br />and completion of wells has the potential to affect groundwater <br />quality. The potential affects could occur due to commingling of <br />aquifers along the well bore. No other activities proposed during <br />development of the service facilities have a reasonable potential to <br />adversely affect groundwater. The correct permit conditions <br />protective of groundwater relevant to the potential for commingline <br />along a bore are practice based conditions. The Reclamation Permit <br />Application requires the well casings be cemented along the entire <br />length and thatcement logs be run and mechanical integrity testing <br />be conducted. Each well completion must be certified and a <br />construction report with all logging and testing results provided in <br />accordance with the regulations for Environmental Protection <br />Facilities (Rule 7.3) and the terms of the permitapplica lion. Practiced <br />based permit conditions, by then nature, do not require water <br />quality baseline or monitoring: <br />The activities proposed in the permit application that may affect <br />ground water and that will require permit conditions protective of <br />ground water in the formof numeric protection levels are all related <br />to the requirement to isolate production fluid from the aquifers. No <br />production fluid will be generated until heated barren solution is <br />infected into the mining interval. Injection of solution is prohibited <br />collection during the study will be valid, premining ambient data, <br />which can then be applied in the development of numeric protection <br />levels for ongoing monitoring. In objecting to the approval of the <br />Application, the commentor states that DMG will be vulnerable to <br />pressure to establish less stringent standards if the standards are <br />established after the project is underway. However, there is no <br />subjectivity in the establishment of numeric protection levels. If the <br />ambient quality is at concentrations lower than the groundwater <br />standard for a particular parameter, then the standard becomes the <br />protection level. If the ambient quality is at concentration in excess <br />of the standard, due to natural or preexisting anthropogenic <br />contamination, than the numeric protection level is set at the <br />ambient quality. This narrative standard as well as the table value <br />standards for groundwater are established by the Colorado Water <br />QualityControl Commission. Also, in the case of the American Soda <br />proposal any detectible release of production fluid to groundwater <br />would require corrective action, regardless of whether groundwater <br />standards are exceeded. [Footnote and emphasis added.] <br />AMERICAN SODA -3- BRIEFING PAPER <br />