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SUMMARY The pilot-scale project is an experimental demonstration project to define and prove the technical and economic feasibility of nahcolite solution mining. Techniques and methodologies, such as their proposed well completion and abandonment procedures, need to be allowed by BLM so that the best, most cost effective operational procedures can be proven. 2. The upper and lower aquifers are hydraulically connected in the central Piceance Basin and are, in reality, one aquifer, therefore, there is no reason to isolate them. 3. Their proposed well completion and abandonment procedures are technically proven and will provide adequate protection to resoures of concern (i.e., groundwater and oil shale). BL1vt's well completion stipulation is too costly. BLM has never disagreed with or' misunderstood the experimental intent and demonstrative purpose of WRC's pilot-scale project. However, the terms of the sodium leases held by WRC are very explicit in regard to protection of groundwater and oil shale resources, n:gardless of the type or purpose of development. The environmental impact analysis on the pilot-scale project, just/ az our analysis on the commercial-scale nahcolite project, waz structured and constrained by these leaze requirements (See drak E[S, Appendix E, Sections 2(I), (q); 5(a), (b), (c); and Stipulation No. 12). In regard to the "one versus two" aquifers issue, BLM acknowledges that site-specific evidence seems to indicate that the upper and lower aquifers are hydraulically connected; however, we are not ready to accept matter- of-factly that they are in communication to the extent that they can be considered az a single aquifer. The extent and degree of communication has not yet been qualified or quantified. Therefore, in the absence of more definitive data, prudent management by BLM must be exercised in light of the explicit lease requvements addressing protection of the groundwater resources. BLM had, and continues to have several technical and environmental concerns related to WRC's proposed well completion and abandonment methods. These concems have focused upon the specific intent of the explicit lease terms requiring protection of groundwater and oil shale resources. These concerns are detailed in the Water Resources rewrite (Section 3, TEXT CHANGES) and in BLM's technical evaluation (Appendix B). Pursuant to federal regulations 40 CFR Parts 144 to 147 (az promulgated from the Safe Drinking Water Act), the United States Environmental Protection Agency (EPA) has authority and responsibility to ensure protection of underground sources of drinking water for activities involving the injection of Buids into the ground. EPA is currently analyzing an application for a Class 111 - Underground Injection Control (UIC) permit on WRC's commercial nahcolite project (the Proposed Action). EPA has many of the same technical and environmental concerns expressed by BLM in this document. !t's expected EPA will have a draft UIC permit completed by August 1987. 1.4 Summary of Impacts The following table (Table 2-2) summarizes the potential impacts, by resource, for each of the alternatives as described in the Environmental Consequences section of the drak E1S and the Text Changes section of this document. Impacts which are considered significant are duly noted. 1-3