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<br />Page '?. Larry Shults March 3, 1999 <br />The impacts of subsidence from mining activities on the upper and <br />lower aquifer are not adequately discussed or reflected in a water- <br />monitoring plan. It is our understanding that there are substantial data <br />to suggest that there are presently hydrologic connections between <br />surface hydrology and bedrock hydrology near the project site. The alkali <br />flats area just to the north of this site is an example. In addition, data <br />supplied with the DEIS for this project could suggest that this connection <br />exists as far upstream as the project area. All aquifer systems, including <br />local springs, Piceance Creek, and the Piceance Creek valley fill aquifer, <br />should be included in awater-quality monitoring program. <br />The summary discussion of the cumulative impacts from this <br />project on groundwater (page 5-4) suggests that potential impacts would <br />be local and not regionally significant. This may not accurately reflect <br />the situation. The protection and maintenance of the existing water <br />quality of the region has been identified as a major issue in Rio Blanco <br />County's Master Plan. This project has the potential to impact both <br />surface and bedrock hydrology and could impact water quality locally, <br />regionally, and beyond. For example, any increase in dissolved solids <br />could seriously impact agricultural viability along Piceance Creek as well <br />as local springs and wells used for domestic purposes. Any significant <br />degradation of water quality also could affect future development of <br />nahcolite, oil shale, and other industries in the basin. The aquifers <br />impacted by this project interact with Piceance Creek and ultimately the <br />White River. These rivers are the major source of domestic, agricultural, <br />and industrial water for the western half of Rio Blanco County. The <br />White River also is home to several endangered species of fish and <br />ultimately supplies water to the Colorado River and much of the <br />southwest U. S. The mining and water-monitoring plans for this project <br />should address these potential impacts. <br />Rio Blanco County requests to be a participant in the design of the <br />water-quality monitoring program for this project. This plan should <br />include the establishment of accurate baseline conditions, which <br />includes existing U. S. Geological Survey (USGS) data, EPA QA/QC <br />approved labs or the USGS lab for water analysis, and independent <br />verification of sampling and data analysis. All sampling should be <br />conducted along accepted procedures of the hydrologic community. <br />