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choose well locations at this time for any panels beyond the 0-5 year panel. <br />Operating experience and field data should be used to make suck future <br />determinations. American Soda intends to have monitoring wells in place and <br />collecting baseline data 6 months prior to commencing mining activities in a panel. <br />46. Section 4.4, page 4-6 -Again, how they will monitor for leaks in the evaporation ponds <br />needs to be spelled out here. <br />See Item 23. Leakage will be monitored by a leakage collection system between a <br />double liner. Leakage will be drained to a sump with automatic pumpback and <br />recording. <br />47. Define "adequate freeboazd". <br />Adequate freeboard will be provided to: a) accommodate the normal maximum <br />operating level plus the 100-year (24 hour) precipitation event; b) accommodate <br />wave action on the pond level of (a) without overtopping; and c) provide at least 1 <br />foot of freeboard above the level determined in (b). <br />The Colorado Division of Minerals and Geology (CDMG) will review and approve <br />the design of all ponds. Freeboard requirements may be adjusted as determined in <br />the CDMG review process. <br />48. Monitoring water quality should be included here. <br />TDS and pH in the Piceance Site evaporation pond, Parachute evaporation pond, <br />and Parachute MVR purge pond will be measured and recorded every 6 months. <br />Results will be included in the periodic (monthly or quarterly) reporting to BLM, <br />EPA, and CDMG. <br />49. General -Section 4.0. Describe monitoring for migratory bird losses on evaporation <br />ponds, water quality (salt concentrations) in evaporation ponds and reclamation success, <br />including noxious weeds. <br />A monitoring plan for migratory bird losses has not been completed. American <br />Soda will develop a migratory bird loss monitoring plan in consultation with U.S. <br />Fish and Wildlife Service, BLM, and CDOW. <br />See Item 48 for monitoring evaporation pottd salt concentrations. <br />A reclnmation plan is currently being developed. The reclamation plan will address <br />reclnrnntion success determination and noxioris weed control. Noxiosrs weeds will <br />be controlled by a combinations of rrteassrres designed to prevent their introdr~ction <br />to tl:e project sites and spraying wit{: aBLM-approved herbicide as necessan~. <br />23 <br />