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<br />ARGUMENT AND AUTHORTTIES <br />DMG staff, pursuant to the terms of 2 COLO. CODE REG. §407-1, Rule 6.4.20(9)(b)? is <br />expressly authorized to designate a different form of groundwater quality data collection <br />other than the five successive quarters of data collection prior to permit issuance which the <br />objectors are urging. That Regulation permits DMG staff to specify an alternative method <br />of data collection to support the Application. This is exactly what DMG has done. It has <br />expressly approved the Plan as its chosen method to characterize water quality baseline <br />conditions at the Mine site. <br />In this regard, the Plan provides that baseline monitoring will commence by <br />September, 1999. The baseline monitoring schedule for groundwater monitoring wells <br />includes monthly water level and water quality monitoring fora 13-month (5 quarters) <br />period. Piceance Creek will be monitored in accordance with the current U.S. Geological <br />Survey (USGS) monitoring schedule. Parachute Creek will also be monitored (USGS <br />monitoring of Parachute Creek has not been conducted for over 10 years). Spring and seep <br />surveys and monitoring (if applicable) will be conducted twice per year, corresponding to <br />high flow (spring) and low flow (fall) conditions for the baseline period and duringsolution <br />mining operations. <br />American Soda will use a network of 24 monitoring well completions to monitor <br />groundwater quality and water levels at the Yankee Gulch site for the 0-5 year mine panel. <br />The Upper Aquifer will be monitored at 11 locations, the Lower Aquifer will be monitored <br />at 9 locations, and the Alluvial Aquifer will be monitored at 4 locations. In addition to the <br />10 existing monitoring wells, American Soda will construct 3 new multiple-completion <br />monitoring wells and 3 new alluvium monitoring wells. Two of the proposed alluvium <br />monitoring wells and an existing monitoring well will monitor the water level and quality <br />Z 2 Colo. CODE REC. §407-1, Rule 6.4.20(9)(b)(c), provides in part, <br />(9) Groundwater quality data- <br />(a) <br />(b) submit, at a minimum, groundwater quality data <br />collected during five successive calendar quarters or <br />as specified by the Division, as may be necessary to <br />adequately characterize base line conditions... <br />(c) Analytical detection linuts and groundwater quality <br />parameters must be acceptable to the Office. <br />[Emphasis added.] <br />AMERICAN SODA -4- BRIEFING PAPER <br />