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<br />Comment 11 Without An Accurate Characterrzation Of The Water Quality Contained In <br />The Aquifers Within The Piceance Site A Reclamation Permit Should Not Be Issued <br />(Section G.1.2 -Groundwater, Pg. G-4) <br />Is it possible that the lower aquifer water sample at 1,411 feet was taken subsequent to <br />the well bore being drilled across the Dissolution Surface and into the top of the Saline <br />Zone, thus producing an anomalous high conductivity and TDS values? How many <br />data points were used to define these elevated TDS and Conductivity values? Are these <br />numbers verifiable? Were proper QAlQC protocols followed during the sampling <br />procedures? Were the samples properly preserved? Was the Dissolution Surface core <br />drilled to accurately identify the lower limit of the lower aquifer and the top of the <br />Saline Zone? If not, why not? If not, how could this water sample be indicative of the <br />Lower Aquifer water quality? The values provided by American Soda are contrary to <br />the vast majority of all other hydrologic data in the Piceance Creek Basin for this <br />hydro-stratigraphic interval. If discrepancies exist between existing data and data <br />developed by American Soda shouldn't water quality should be characterized by an <br />independent third party before a Site Reclamation Permit is considered? <br />Comment 12 Without An Accurate Characterization Of The Water Quality Contained In <br />The Aquifers Within The Piceance Site A Reclamation Permit Should Not Be Lzstred <br />(Section G.1.2 -Groundwater, Pg. G4) <br />How many data points (number of times the specific hydrologic interval was sampled) <br />were used to quantify the water quality of the ground water? Has the USGS developed <br />any water quality data that American Soda could access and, if so, how does the data <br />compare? <br />Comment 13 Without An Accurate Characterization Of The Water Quality Contained In <br />The Aquifers Within The Piceance Site A Reclamation Permit Should Not Be Issrred <br />(Section G.1.2 -Groundwater; Tables G2 and G3, Pgs. G6, G'n <br />If in fact the drill holes penetrated the uppermost part of the Saline Zone, then the <br />lower aquifer water quality data would be inaccurate and misleading. What precautions <br />were taken to avoid this type of problem? Was the zone between the leached area and <br />the Saline Zone cored to accurately identify the Dissolution Surface? If not, why not? <br />Is it not possible that the lower most portion of the lower aquifer could actually have <br />far better water quality than what has been reported by American Soda? Since <br />discrepancies exist between existing data and data developed by American Soda, water <br />quality should be characterized by an independent third party before a Site Reclamation <br />Permit is considered? <br />Page 4 <br />