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<br />nahcolite now with the intent to protect oil shale in the saline zone is unwarranted, particularly <br />since solution mining of nahcolite may actually serve to better prepare [he oil shale for retorting <br />by rubblizing the oil shale matrix. Also, BLM, which is the aeency charged with managing U.S. <br />owned oil shale minerals in the American Soda lease area, must autonomously approve nahcolite <br />solution mining before operations could occur under the terms of a reclamation permit issued by <br />the Board. <br />Comment #17: Why is only the upper aquifer of concern to American Soda when the entire <br />hydro-stratigraphic interval should be of concern and consideration? <br />DNIG Response: The ground water characterization plan will include the entire <br />hydrostratigraphic sequence. The ground water protection measures to be employed are <br />predicated on complete containment of process solution, either in the mining cavities or in cased <br />wells, surface piping, tanks, or lined ponds. Thus release of mine fluids to any aquifer would be <br />a transgression of the practice based permit conditions protective of ground water and would <br />have to be mitigated. <br />Comment #18: What if an underground fault or fracture is intersected during drilling and/or <br />during solution mining activities? <br />DMG Response: The reclamation permit application specifies that if faulted or fractured zones <br />aze encountered in the drilling of a production well, and if geophysical logging indicates that [he <br />formation would not be mineable and no other measures may be taken to put the well into <br />successful production, the well will be plugged and abandoned. <br />Comment #19: What will happen if the hypersaline evaporation ponds fail or flood? <br />DMG Response: The evaporation ponds, if built, will be Environmental Protection Facilities. <br />They will be designed for stability and dam safety, with appropriate safety factors and <br />incorporating an appropriate inflow design flood freeboard. Their design, construction, and <br />certification will be regulated by DMG as with any Environmental Protection Facility. <br />Comment #20: The applicant's reclamation permit application, as written, violates the statutory <br />requirement of gathering baseline data before the issuance of a reclamation permit. Baseline <br />data cannot be collected concurrently with the development of the Applicant's project as is <br />outlined in the reclamation permit application. Both the drilling and development of wells and <br />the well completion methodologies may cause ground water contamination. <br />DMG Response: It is DMG's position that the reclamation permit for the Yankee Gulch Project <br />may be issued and that development of surface facilities and drilling of production wells may <br />proceed concurrently with the collection of baseline ground water data. <br />Rule 3.1.7(3) specifies that permit conditions protective of ground water be established for <br />operations that have a reasonable potential to adversely affect ground water quality. Such permit <br />conditions may be in [he form of numeric protection levels, practice-based permit conditions, or <br />7 <br />