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<br />data appear to be anomalous and will advise them that care should be exercised in <br />reviewing these data. The notice sheet will specifically indicate that interpretation of <br />data from well 20-1 is problematic and that the assessment of Lower Aquifer water <br />quality based on these data should be done with caution. The draft monitoring plan <br />and the notice sheet will be provided to the EPA and the Colorado Division of Minerals <br />and Geology (CDMG) prior to issuance of their respective commercial permits, and <br />documentation of these actions will be provided to RBC. <br />American Soda is committed to working with RBC and the other agencies to <br />cooperatively address their concerns in the groundwater monitoring program. <br />American Soda has retained the services of Bishop-Brogden Associates, [nc., a water <br />resources consultant specializing in groundwater, to assist in the development of the <br />final monitoring plan. American Soda will include monitoring provisions for the <br />Piceance Creek Alluvial Aquifer and local springs, as determined through consultation <br />with the various agencies. Specific locations, numbers, and sampling frequencies of <br />these systems will be determined as part of the final monitoring plan. American Soda <br />intends that the final monitoring program will be a dynamic and flexible plan that may <br />be altered based on the results of future data collection and in cooperation with the <br />permitting agencies. After the monitoring program is implemented, American Soda <br />will produce annual data reports and provide the reports to the agencies. American <br />Soda will periodically provide analytical results to RBC and other agencies on a timely <br />basis throughout the year or upon request. <br />American Soda is committed to protecting groundwater quality in the Piceance Creek <br />Basin. As we have discussed with RBC and other agencies, American Soda will take <br />appropriate and effective measures to protect groundwater quality including the <br />following. <br />• Effective well completions to isolate aquifer systems, including the use of tubing <br />inside properly cemented casing, logging to evaluate the adequacy of well completions, <br />and mechanical integrity testing of wells prior to operation. <br />• Operational monitoring of the pressure and flow in and out of wells to evaluate <br />potential leakage and detect well failures. Isolation of the solution mining cavity is <br />required for the mining process to work. If pressure cannot be maintained on a well, <br />the well cannot be mined. <br />• Establishment of a roof zone above each cavity to further isolate the mining <br />horizon from the aquifer systems. The roof zone will be approximately 150 feet thick. <br />• Completion of a final groundwater monitoring plan that is both economically <br />feasible and technically viable. The monitoring plan will include the proper collection <br />Water Quality 1-2 <br />Rio Blanco County Additional In(ormanon Request <br />Piceance Muting Operatlon <br />American Soda, L.LP. <br />