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~. <br />constituents in the Dissolution Zone because water in that unit is saturated with respect to <br />nahcolite at the formation temperatures and pressures and tends to precipitate at the lower <br />temperatures and pressures up hole. This makes sampling difficult to impossible in some cases; <br />it does not provide an accurate measure of major dissolved constituents in the formation; and it <br />may produce conditions whereby trace constituents will show erratic results due to differences in <br />the way samples are collected and to variations in atmospheric temperatures. While the proposal <br />does not call for NPL's for the Dissolution Zone, it does call for reporting of parameters, and it is <br />likely that there will be occasions when it will not be possible to collect waters from that unit. I <br />would recommend that the reporting requirement for chemicals in the Dissolution Zone be <br />changed to "report when possible." <br />Having reviewed the captioned document, I would recommend that the Division accept the <br />parameters and sampling frequencies as proposed by the Operator. <br />cc: Carl Mount <br />Bruce Humphries <br />