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F'1 1 violate surface or groundwater quality standards. As demonstrated, however, the proper test is whether the toxic-forming materials could have an adverse impact, not whether they will violate water quality standards. In addition, no analysis has been provided regarding DMO status being triggered by the hydrological impacts of dewatering the ore bearing layer. Also, public records indicate the presence of intermittent streams and surface water expressions located at the site which require erosion and flow control for these same toxic-producing materials. Further, there is no analysis in the file regarding such important matters as radiological and other hazards posed by the uranium ore whether exposure occurs on site or off site. At a minimum, in order to qualify as exempt from DMO status, the Boazd and Office must assess the potential for adverse impacts resulting from these aspects of the SM-18 Mine. In sum, the DMG improperly granted anon-DMO finding under the exemption standards where DMG should have instead upheld the DMO determination and required the operator to file an application for DMO exemption for formal review and consideration by the MLRB. Appellants Colorado Environmental Coalition (CEC) is a Colorado-based environmental advocacy organization with three field offices in western Colorado and a main office in Denver. CEC has approximately 3,500 individual members and over 90 affiliated organizations. CEC campaigns engage citizens in the protection of Colorado's wild places, open spaces, wildlife and quality of life. CEC is a known and active participant in public land management in Colorado, with a demonstrated interest in energy development on Colorado's BLM lands. CEC members are concerned with protecting wildlife, scenery, water quality, quality of life, and other values. Information Network for Responsible Mining (INFORM) is a nonprofit organization with the mission of educating the public about the dangers that exist when unsafe and irresponsible mining practices are permitted. Through the dissemination of information and education, INFORM helps organize residents in local communities most threatened by these practices to protect water quality, quality of life and the local economy. The San Juan Citizens Alliance was founded in 1986 as a voice for environmental, social, and economic justice in the San Juan Basin of southwest Colorado and northwest New Mexico. San Juan Citizens Alliance works toward the protection of the wild lands, greater corporate and governmental responsibility in the development of natural resources, and for the protection of the waters in the Basin and includes more than 500 members who live in and who care about the natural and human resources of the basin. Conclusion Appellants request that the MLRB find that the SM-18 is a DMO, reinstate the July 25, 2005 DMO determination, and required the operator to immediately take all necessary steps to comply with DMO-based regulation.