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<br />Comment 13 (Continued) <br />Why isn't there any water quality data for specific hydro-stratigraphic units between the <br />depths of 811-1411 feet? Why wasn't this 600 foot interval ever sampled? What is the <br />water quality throughout this hydro-stratigraphic sequence? The water quality must be <br />properly characterized before a Site Reclamation Permit is considered. <br />Why weren't these tables and groundwater data presented and relied upon in the Draft <br />Environmental Impact Statement? <br />Comment 14 The Division of Minerals and Geology Must Ensure The Integrity Of The <br />Site Reclamation Permitting Process By Requiring Reliable And Verifiable Data (Section <br />G.1.2 -Groundwater, Pg. GS) <br />How many data points were used to define the USDW? Were these samples properly <br />preserved and transferred to the laboratory in a timely fashion to meet proper <br />protocols? Are these data verifiable? One water quality sample of questionable <br />validity should not be relied upon to determine an USDW. Why does American Soda <br />present these data as such and will there be a third (independent) party involved to <br />verify water levels, water quality and proper protocols? The Division of Minerals and <br />Geology must ensure that the integrity of the Site Reclamation Permit process is <br />preserved and resolve any differences in water quality between existing data and data <br />developed by American Soda. <br />Comment 15 The Division of Minerals and Geology Must Ensure The Integrity Of The <br />Site Reclamation Permitting Process By Requiring Reliable And Verifiable Data (Section <br />G.2.2 Groundwater Quality Effects, Pg. G10) <br />If the aquifers beneath the American Soda lease have not been adequately defined, <br />delineated, and chazacterized, is it not premature to state the only USDW is in the <br />Unita Formation? What is the water quality of the area between the Mahogany Zone <br />and 1350' below grade? How many specific water quality samples have been used to <br />define the aquifers and were these samples taken under proper QA/QC protocols? <br />Comment 16 The Potential For High TDS Contamination Of Aquifers Should Be <br />Addressed (Section G.2.2 Groundwater Quality Effects, Pg. G9) <br />What "corrective action" would be taken if the wells and/or cavities leaked high TDS <br />fluids into the aquifers? <br />Page 5 <br />