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<br /> <br />thereby ensuring the testing methods used will adequately meet the Basic Standards for <br />Groundwater. Tables WQ1 and WQ2 were revised to incorporate the required conditions and <br />submitted to CDMG as a Technical Revision to the 112 Permit on September 16, 1999. <br />The issue of high MDL levels in the ground-water monitoring plan was discussed <br />extensively by commentors at the July 13, 1999 Public Hearing held in Meeker, Colorado. As a <br />result of EPA's review of the Water Monitoring plan, comments from various parties and <br />discussions with the BLM and the CDMG, EPA has required American Soda to modify the <br />April 22od plan to incorporate the new MDL requirements as established by the 112 Surface <br />Reclamation Permit issued to American Soda by CDMG. A revised Water Monitoring <br />Plan was submitted on December 23, 1999. This will ensure that a consistent analytical <br />approach is utilized for the collection of data required by all regulatory agencies. It is important <br />to note, however, that the actual detection or quantification limits obtained on high TDS ground- <br />water samples will most likely be higher than the laboratory determined MDLs and PQLs. This is <br />due to possible matrix interference and the need for dilution of the samples prior to analysis. In <br />that case, the laboratory MDLs and PQLs would need to be adjusted upwazd to account for <br />sample dilution. <br />Because of the potential need for modifications of both the Subsidence and the <br />Water Monitoring Plans during the life of the Permit, EPA has modified the Permit to <br />adopt both the Subsidence and Water Monitoring plans into the Permit entirely. The <br />applicant was required to submit revised Water Monitoring and Subsidence plans which <br />incorporate changes made by CDMG ,BLM and EPA in response to public comments and <br />requests made by Rio Blanco County. These revised plans are incorporated as appendices <br />to the Permit. Any significant modifications in either of those plans deemed necessary as a <br />result of on-going monitoring during the life of the Permit will be made by modifying the <br />Permit as provided in 40 CFR 144.39 and 40 CFR 144.41. <br />The Draft Yankee Gulch Permit required at least six (6) months of additional baseline <br />monitoring data prior to commencement of commercial mining. As a result of discussions <br />between the various regulatory agencies and American Soda, the baseline monitoring <br />requirements have been modified. The monitoring plan now provides for five quarters of baseline <br />monitoring prior to commencement of injection. This will provide a baseline picture over a one <br />year period. This will establish a water quality record for both the high and low recharge periods <br />so that the seasonal variation ofthe aquifers can be accounted for when making a comparison <br />with operational monitoring data. Although EPA believes that these baseline data will be <br />adequate for comparative purposes, the data collected will be reviewed prior to the <br />commencement of injection. Additional data maybe required, if necessary for comparison <br />purposes. <br />The Water Monitoring Plan dated Apri122, 1999, provided for initial monitoring at 23 <br />well completions for the first five- yeaz mine panel. The upper aquifer would be monitored at 11 <br />locations, the lower aquifer at 8 locations, and the alluvial aquifer at 4 locations. The Uinta <br />Formation itself will be monitored at 6 locations. The revised Water Monitoring Plan now <br />20 <br />