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well spacing designed to ensure cavity stability and process and environmental monitoring to detect development of any leakage. A key component of the EPA`s UIC permit is to protect underground sources of drinking water through continuous monitoring of injection pressures, flow rates and total volumes injected, it specifies groundwater monitoring locations to detect potential impacts to water quality, requires reporting of noncompliance or process malfunction with 24 hours, and stipulates enforcement under the Safe Drinking Water Act. A "Groundwater and.Surface Water Monitoring Plan" has been prepazed in consultation with the BLM, CDMG, USGS, EPA and Rio Blanco County, and is designed W detect any changes in water quality in Piceance Creek and surrounding springs and s'.eps. 'This plan establishes a framework for monitoring groundwater quality and the establ'iishment of baseline data and trends such that any deviation from established characteristics is recognizable. Corrective actions established for all data excursions involve a basic strategy of discontinuing processes until best correction actions can be determined and implementecl in cooperation with the CDMG, EPA and BLM. Monitoring of groundwater in the vicinity of the mine panels as described in a "Groundwater and Surface Water Monitoring Plan" would detect and allow opportunities. to mitigate groundwater adversely affected by mine operation before it has migrated to potential dischazge points along Piceance Creek. The likelihood for groundwater with elevated TDS to enter Piceance Creek is considered low. The 13-month baseline data collection program is scheduled to commence in September 1999. The monitoring plan includes plans for water level measurement and water analyses applied to a network of groundwater wells (24 on Piceance site and at least 1 doWmgradient from Pazachute evaporation pond), surface water stations, and production facilities. A State of Colorado certified laboratory will be used for all water quality analysis. Preference will be given to USGS's Water Resources Division analytical laboratory in performing annual third- party data validation. Water Supvly Svstem Since recently learning that the Rifle to Palisade reach of the Colorado River is scheduled for razorback and pikeminnow recovery activities beginning as eazly as this yeaz, BLM considered it appropriate to expand our impact discussion to potential direct impacts associated with impingement andJor entrainment of fish at the river intake. For this reason, a more detailed account of the rivet withdrawal system is provided. American Soda's design for a process water supply system is somewhat different than that presented in the original BA. What is presented here is consistent with, bu.t more detailed than that described in the Draft EIS. The project's primary source of water will be Unocal's existing alluvial well field located at the forks of East and West Parachute Creek. This well system has been operative since Unocal closed it's facility in 1991. At tunes, agricultural irrigation considerations in the Pazachute valley and insufficient well production would require the employ of an alternate water source. American Soda intends to reactivate Unocal's existing river intake system which pumps water duectly from the middle of the Colorado River about 1 mile northeast of the town of Pazachute (see attached map). Water is gravity fed from the mid-channel crib to an onshore sump through a pair of 48-inch pipes. Water is