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CNAPTERFOUR Enuironmenta~ conseuuences ' Piaeliae , A potential release from the product pipeline could impact alluvial waters that exist along the pipeline corridor. Due to the relatively shallow depth of the pipeline installation (3 feet below ground), the pipeline construction of steel with three layers of insulation, and low seismicity, a , pipeline breach or leak is unlikely. Adverse impacts to groundwater aze unlikely. Parachute Site , At the Pazachute Site, an evaporation pond would be used to hold water discharg:d from the cooling tower, boiler, and dischazge from the process water treatment plant. This; evaporation ' pond would likely contain water with elevated TDS concentrations. Although ths pond would be lined, the potential exists for the release of the higher TDS water into the alluvimn of Pazachute Creek if the liner were to fail, but the planned leak detection monitoring and recovery/pump-back ' system would help minimize releases to groundwater. Accelerated Development Alternative ' Potential effects to groundwater quality and quantity would be similar to the Proposed Action. No Action Alternative Under the No Action Alternative, only the experimental test mine and associated structures would exist at the Piceance Site. Monitoring wells established under the BLM-approved Test Mine Plan will be utilized to determine if production fluids from these activities enter the groundwater system at the site. 4.4.3 Mitigation The mitigation measures proposed aze related to the potential impacts described in Section 4.4.2. ' These potential impacts would occur from mechanical, operator, or some other type of failure of the system that would allow a release of production fluids or other materials that contained elevated TDS concentrations. A release could potentially be caused by production well casing leaks, solution cavity leaks, pipeline leaks or ruptures, or from leakage from the onsite evaporation ponds. To determine whether releases have occurred, to evaluate the impacts from a potential release, and to design mitigation measures, monitoring of the solution mining operations is necessary. Casing construction and monitoring are regulated by the EPA under the Underground Injection ' Control (UIC) Regulations for Class III injection wells (40 CFR 146.33). Well failure criteria were established during the experimental mining program (Steigers 1998c), and these criteria were submitted to the EPA for approval under the UIC program. These criteria define ' relationships that may indicate well failure or instrumentation failure. Should an~~ of the criteria be reached, then a Well Failure Response Plan would be implemented. This plan is currently under development by American Soda and would be formulated in conjunction with appropriate agencies. At a minimum, specific corrective action procedures following instrumentation, casing, and other well integrity verification procedures should include: 4-16 Groundwater ,