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2004-09-08_REVISION - M1999002
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2004-09-08_REVISION - M1999002
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Last modified
6/16/2021 6:21:16 PM
Creation date
11/21/2007 10:29:10 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1999002
IBM Index Class Name
Revision
Doc Date
9/8/2004
Doc Name
Mod.- Ground Water Monitoring Plan
From
American Soda LLP
To
DMG
Type & Sequence
TR4
Media Type
D
Archive
No
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12 <br />mining into a fault or fractured zone. The concentration of the constituents in the <br />solution mining brine shows some key indicators that are markedly greater in <br />concentration when compared to the various concentrations of these same <br />constituents derived from the overlying aquifers. In other words, it is expected <br />that in the event of contact between the brine solution and the overlying aquifers, <br />analysis of these indicator parameters in the ground water system would show <br />evidence and extent of contamination from brine solution as a result of the <br />comparative concentration differences. <br />The data representing each of these constituents is presented in the tables in <br />Appendix A. Following each Table is a series of graphs showing the historical <br />concentration of the constituents in each water bearing zone during both baseline <br />and operational periods. The final graph in each of these series is a compilation <br />of all zones and the production streams. In each compilation graph the markers <br />identifying the production streams are visibly higher in concentration than the <br />aquifer concentrations. It varies by as much as an order of magnitude to as little <br />as a factor of 2. <br />In order to establish numeric protective levels that are protective of the <br />environment at points of compliance the highest values recorded during baseline <br />monitoring that are not excluded as outliers using the Dixion test statistical <br />method will be used as Permit Condition Values unless a regulatory standard is <br />applicable. It is expected, as has been observed in the previous five year <br />monitoring period of record, that occasional data values will vary slightly above <br />this conservative level intermittently. At points of compliance, verification <br />samples will be collected as previously discussed. The frequency for the first <br />verification sample will be in the month immediately following the quarterly <br />elevated value during commercial operations and in the month following the <br />second elevated quarterly value during interim status. If necessary a second <br />verification sample will follow in the subsequent month until normal <br />concentrations are observed. Corrective action will be initiated if it is determined <br />that it is necessary for protection of ground water. One exception should be <br />noted, dissolved silica at well 20-8 will not have an established early warning <br />indicator. The concentration of dissolved silica at well 20-8 was effected during <br />the baseline period by pumping of this well to supply water for the cement work <br />on the commercial plant foundation. Silica values during baseline are not <br />considered representative of static conditions in the well due to the pumping <br />during this baseline period. <br />At all other monitoring locations, (non-point of compliance), the variation will be <br />noted in the report and comparisons will be made with the next regularly <br />scheduled sample. At anon-point-of-compliance monitoring point verification <br />sampling will not be initiated until two consecutive quarterly samples show values <br />above the early warning indicators established as permit condition values. At up- <br />gradient monitoring points no early warning indicators or numeric protective <br />levels will be established. These up-gradient points are vital to the overall <br />
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