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Page 2, Larry Shults September 9, 1999 <br />characterization of this site. The water-quality monitoring plan also <br />should address possible plumes of contamination to provide meaningful <br />information in the review of potential impacts from this mining operation. <br />Minimum detection limits (MDLs) in the Groundwater Monitoring <br />Plan (Vol. 11, appendix G, tables 2, 3 and 5) for several constituents are <br />too high to be useful for monitoring. It is suggested that MDLs be <br />consistent with previous USGS data in the Piceance Basin or below <br />expected levels from undisturbed groundwater in the basin. <br />' The use of statistical methods where mean concentrations for the <br />American Soda data were determined by using one-half the detection <br />limit for all non-detect analysis (Vol. 1, 5-15) is inappropriate for <br />developing baseline hydrology at the project site. Results calculated this <br />way are misleading and inaccurate information. This method is <br />especially inappropriate where high MDLs have been used. <br />Rio Blanco County appreciates the cooperation of the BLM and <br />American Soda, L.L,P. in working to resolve the issues we have raised. <br />If you have any questions please contact the Rio Blanco County <br />Development Department. <br />Sincerely, <br />~ /~~~~ <br />Jim Komatinsky, Director <br />Department of Development <br />cc: RBC Board of Commissioners <br />George Benner, Atty. <br />American Soda, L.L.P. <br />Carl B. Mount, DMG <br />Cynthia Cody, EPA <br />Paul von Guerard, U.S.G.S. <br />Enclosure: "Groundwater Quality in Piceance Creek Basin" <br />By G: J. Saulnier, Jr. (September 7, 1999) <br />